HUD MOR CHANGES?
HUD is seeking comment on changes that impact HOTMA, VAWA, and MOR documentation.
HUD is proposing updates to the paperwork used for Management and Occupancy Reviews (MORs) of multifamily housing projects.
The August 4, 2026, Federal Register notice does not create a new MOR rule. Instead, HUD is seeking approval to revise HUD Form 9834, Management Review for Multifamily Housing Projects, and incorporate HUD-91067, the VAWA Lease Addendum for Multifamily Housing Programs, into the information collection.
However, the proposed revisions are worth owners’ and agents’ attention now. The updated HUD-9834 would make several current compliance areas more explicit during an MOR, including HOTMA, physical inspections, and VAWA.
Comments on the information collection are due September 3, 2026.
Proposed HUD Management Review Changes
First, owners and agents should understand what this notice does—and does not—do.
This is a 30-Day Notice of Proposed Information Collection under the Paperwork Reduction Act. HUD is asking the Office of Management and Budget to approve the revised collection.
Therefore, HUD is not announcing a new final MOR rule through this notice. Moreover, the proposed forms should not be treated as final until the review process is complete.
Instead, HUD is asking whether the information is necessary, whether its burden estimates are accurate, whether the forms are clear, and whether technology could reduce the administrative burden.
For owners and agents, however, the draft forms provide an important look at what HUD wants its management review tools to examine more directly.
What Could Change on HUD Form 9834
The overall purpose of an MOR would remain the same. Reviewers would continue evaluating property management, leasing and occupancy, financial management, inspections, tenant relations, and other areas.
However, the proposed HUD-9834 would make several newer requirements much more visible.
Proposed Changes Includes HOTMA Questions
The proposed form includes more detailed questions about Housing Opportunity Through Modernization Act (HOTMA) requirements.
For example, reviewers could examine tenant files and procedures involving:
- Income and asset limits
- Asset self-certification
- Verification of self-certified assets
- Actual and imputed income from assets
- Safe-harbor income determinations
- Applicable deductions and allowances
- Hardship provisions
- Asset limitations
- Income and rent calculations
As a result, owners and agents should expect HOTMA implementation to become a more explicit part of the MOR checklist if HUD finalizes the form as proposed.
That does not mean this notice creates the underlying HOTMA requirements. Rather, HUD is proposing to incorporate those requirements more directly into the management review process.
Physical Inspection Terminology Would Also Change
HUD also proposes updating the physical inspection portion of Form 9834.
For example, the revised form asks about the property’s most recent physical inspection and whether it identified Life-Threatening or Severe conditions. It also asks whether deficiencies were corrected and whether recurring problems exist.
Consequently, inspection follow-up documentation could become especially important during MOR preparation.
Owners and agents should be able to show not only what an inspection found, but also how and when identified deficiencies were addressed.
HUD Management Review Changes Include Dedicated VAWA Review
One of the most significant proposed changes involves the Violence Against Women Act (VAWA).
The proposed HUD-9834 includes a dedicated Addendum E: Violence Against Women Act Review.
Under the proposed review structure, reviewers could examine whether an owner or agent:
- Uses the applicable VAWA lease addendum
- Maintains written lease bifurcation procedures
- Provides required VAWA notices and certification forms
- Protects confidential VAWA information
- Maintains a written emergency transfer plan
- Has procedures for internal and external emergency transfers
- Properly documents VAWA-related requests
- Retains required VAWA documentation in tenant files
In addition, reviewers could sample actual tenant files involving VAWA protections, emergency transfers, rejected applications, terminations, or evictions.
Therefore, the review would look beyond whether a property has a written VAWA policy. Reviewers could also examine whether staff followed that policy in practice.
The Proposal Includes an Updated VAWA Lease Addendum
HUD is also proposing to bring HUD-91067, the VAWA Lease Addendum for Multifamily Housing Programs, into this information collection.
The proposed addendum addresses protections involving admission, assistance, eviction, termination, confidentiality, emergency transfers, lease bifurcation, retaliation, and requests for documentation.
The form would be signed and retained in the tenant file.
This is also responsible for most of the dramatic increase in responses shown in HUD’s paperwork estimates. HUD estimates 27,127 annual HUD-9834 responses and 413,929 HUD-91067 responses.
In other words, HUD is not proposing more than 400,000 MORs. Most of those responses represent VAWA lease addenda.
What Should Owners and Agents Review Now?
Because the revisions are still proposed, owners and agents do not need to treat the draft HUD-9834 as a new final checklist.
Nevertheless, it can serve as a useful preview of the documentation HUD wants to examine more closely.
Consider reviewing:
- Current HOTMA policies and tenant-file procedures
- Income, asset, deduction, and hardship documentation
- Physical inspection reports and evidence of corrections
- VAWA policies and confidentiality procedures
- Emergency transfer plans and related procedures
- VAWA notices and certification forms
- Lease addenda and tenant-file controls
- Staff training on HOTMA and VAWA requirements
Additionally, owners and agents may want to compare their existing MOR preparation procedures with the proposed HUD-9834. Doing so can help identify documentation or training gaps before the revised form becomes final.
What Happens Next?
HUD is accepting comments on the information collection through September 3, 2026.
The agency is specifically asking for feedback about the necessity of the collection, its estimated burden, the clarity of the forms, and ways to reduce the administrative burden.
Owners, agents, contract administrators, industry organizations, and other stakeholders may therefore want to review the proposed forms and determine whether any provisions need clarification.
Navigate will continue monitoring HUD’s action on the information collection. Until HUD completes the process, owners and agents should continue following current HUD requirements and applicable guidance.
Suggested FAQs
Are the proposed HUD management review changes final?
No. HUD’s August 4, 2026, notice seeks OMB approval for revisions to the information collection. Owners and agents should continue following current HUD requirements while monitoring the proposal.
What is HUD Form 9834?
HUD Form 9834 is used during Management and Occupancy Reviews of multifamily housing projects. It helps reviewers evaluate property management, leasing and occupancy, financial management, inspections, tenant relations, and other program requirements.
How could HOTMA affect future Management and Occupancy Reviews?
The proposed HUD-9834 includes more explicit review questions involving assets, income determinations, deductions, hardship provisions, and other HOTMA-related requirements.
What VAWA documentation could reviewers examine during an MOR?
The proposed form could direct reviewers to examine VAWA policies, notices, emergency transfer procedures, confidentiality practices, lease addenda, and selected tenant files.
When are comments on HUD’s proposed HUD-9834 revisions due?
Comments on the 30-Day Notice of Proposed Information Collection are due September 3, 2026.
