Multifamily property owners and agents around the country are busy preparing for the implementation of HOTMA on property.

In case you missed it, HUD NOTICE 2023-10 grants an extension for HOTMA to roll out on properties.

HUD NOTICE 2023-10, extending the Implementation Guidance for Sections 102 and 104 of the Housing Opportunity Through Modernization Act (HOTMA) of 2016, has become a pivotal point of interest for housing policy experts, advocates, and individuals seeking assistance.

This comprehensive 110-page notice offers crucial insights into the implementation of HOTMA.

HOTMA Implementation: What is it?

The Housing Opportunity Through Modernization Act (HOTMA) of 2016 is a landmark piece of legislation. It is designed to reform and improve several key housing assistance programs administered by HUD. These programs include the Section 8 Housing Choice Voucher Program, Public Housing, and various related initiatives. The primary goal of HOTMA is to make housing assistance more efficient, flexible, and responsive to the needs of low-income individuals and families.

Also, the implementation of HOTMA requires most documents owners and agents are familiar with to be updated. One of the biggest will be the Tenant Selection Plan.

Owners and agents preparing for the implementation of HOTMA should also update EIV policies & procedures, House Rules, and owner’s discretionary policies. In addition to document changes, the implementation of HOTMA will change requirements for the collection of signatures on certain documents.

Does Notice 2023-10 Change Anything?

Ultimately, the biggest takeaway from HUD Notice 2023-10 is that it extends the implementation window. Page 14 of the notice issues a clarification on asset limits.

HUD NOTICE 2023-10 underscores the significance of compliance and timely updates. Housing providers, particularly Multifamily Housing Office/Agents (MFH O/As), are expected to align their Tenant Selection Plans and EIV (Enterprise Income Verification) policies and procedures with HOTMA rules and discretionary policies by March 31, 2024.

Several asset disqualifiers now impact applicants and households already in place on property. The first is asset caps disqualifier. Under the new rule, households with assets in excess of $100,000 are ineligible. Ownership of real property is also often a disqualifier. However, there are a few exceptions to the rule to consider.

• Is the property in question owned jointly?
• Is this property safe to live in?
• Does this property meet this disability needs of the resident?
• Is the property sufficient for the size of the family?
• Finally, does property creates a geographic hardship on the family?

There are many factors involving Asset Limitations under the HOTMA rule. HUD recently issued this clarification for property owners and agents.