It is time for owners and agents to revisit and revise Tenant Selection Plans. (TSP) In this week’s #TuesdayTip, how to make sure your plan aligns with the latest HOTMA guidance.
Where to Begin Your Tenant Selection Plan?
Under HOTMA, some recommendations are now requirements. Please reference the HUD Handbook, particularly Chapter 4, where both required and recommended topics for plans can be found can be found. Now that HOTMA implementation is moving forward, HUD recommends moving discretionary policies directly into the TSP.
Owners & Agents should begin revisions with new HOTMA information including the $100,000 threshold. Additionally, this update should extend to procedures for accepting applications, selecting tenants from the waiting list, and rejecting ineligible applicants. Please reference figure 4-2A in the HUD Handbook.
Next, owners & agents should update policies regarding student eligibility and the application of the Violence Against Women Act (VAWA). This includes incorporating new forms and directives from HOTMA.
Please consult HUD’s list of discretionary policies for multifamily housing to address additional concerns. As you are revising your plan, take a close look at HOTMA specific updates. These include de minimis error and self-certification of net family assets with a threshold of $50,000 or less. You can also detail specifics on hardship exemptions, including those related to health, medical expenses, child care, and phased-in relief for families affected by recent changes.
Address the impact of HOTMA on interim re-examinations, including adjustments to income, reporting changes, and effective dates of these changes. Do not forget to highlight the revocation of consent forms, the new requirements for means-tested verification (Safe Harbor), and the implementation of new verification methods and hierarchies in the TSP. These changes are crucial for maintaining compliance with HOTMA and HUD guidelines.