HUD recently extended the full compliance deadline for HOTMA Sections 102 and 104 to January 1, 2027. Now, housing providers have valuable time to prepare. In this week’s Tuesday Tip, we encourage housing providers to use the extra time to reinforce strong verification practices on property.
In multifamily housing, verification has always been about confirming the core facts that determine eligibility. This includes verifying:
- Household composition
- Social Security numbers
- Dates of birth
- Names and relationships
These elements must be supported by reliable documentation. As HUD has clarified, reliable documents submitted directly by the tenant are acceptable, as long as they meet program standards and are properly documented.
This flexibility is especially important as owners prepare for HOTMA-related changes to income and asset calculations.
Income Verification: Make it Traceable
This Tuesday Tip emphasizes income verification must be both current and understandable. Best practices include:
- Review the most recent four to six pay stubs
- Clearly explain any unusual or complex income situations
- Document all third-party responses—or lack of response—in writing
If another staff member, auditor, or reviewer opens the file later, they should be able to follow the income story without confusion.
Pre HOTMA Verification: Documentation Should Tell the Story
Strong documentation does more than prove compliance—it explains decision-making.
A well-documented file should:
- Include all required verification materials
- Clearly tie documents to eligibility factors
- Explain discrepancies, judgment calls, or “bizarre” income situations
Again, files should easily tell a story that others can understand. This point becomes even more critical as HOTMA will reshape income determinations, net family asset treatment, deductions, and hardship relief.
HUD’s recent extension of the HOTMA compliance deadline gives owners a full year to prepare, but it should be viewed as risk management, not a reason to delay.
As we’ve mentioned, HUD’s HOTMA compliance extension, 2026 should be treated as a build year—a time to strengthen verification checklists, align forms, test software outputs, and standardize file notes before HOTMA becomes mandatory.
Strong pre-HOTMA verification practices create the consistency needed for:
- Smoother HOTMA implementation
- Accurate certifications
- Reduced resident disruption
Verification fundamentals remain the same—even as HOTMA approaches. Housing providers should continue to:
- Verify household composition and eligibility carefully
- Use reliable, tenant-submitted documents appropriately
- Document all decisions clearly and consistently
- Ensure every file tells a complete, logical story
Input from housing professionals remains critical. Raising real-world scenarios and verification challenges now helps strengthen guidance, improve consistency, and reduce errors as HOTMA implementation moves closer. Click Here for more HOTMA Resources from HUD.
