On May 30, 2025, the Office of Multifamily Housing Programs issued a new Housing Notice extending the mandatory compliance date for the Housing Opportunity Through Modernization Act of 2016 (HOTMA). The previous deadline of July 1, 2025, has now been extended to January 1, 2026, for all owners participating in HUD multifamily project-based rental assistance programs.

What This Means for Owners and Agents

• Full HOTMA compliance is required for all tenant certifications dated on or after January 1, 2026. This includes adherence to both the mandatory provisions and any discretionary policies implemented by owners.
• Owners and agents may voluntarily adopt HOTMA compliance earlier by utilizing the rent override function in the Tenant Rental Assistance Certification System (TRACS).

Interim Compliance Guidance

Until a property fully implements HOTMA, HUD advises the following:

• Continue to follow your current Tenant Selection Plan (TSP) as approved by HUD or your Contract Administrator.
• Maintain adherence to existing Enterprise Income Verification (EIV) policies and procedures.
• Ensure any early implementation steps are consistent with TRACS capabilities and accurately documented in tenant files.

Key Takeaways

• New HOTMA compliance deadline: January 1, 2026
• Optional early adoption is available through TRACS
• Existing policies remain in effect until full HOTMA compliance is achieved

LIHTC Impact

Owners and operators of LIHTC projects should contact the relevant Housing Finance Agency (HFA) for information on the effective date in their respective states.

If you have any questions regarding the HOTMA implementation timeline, updating your policies, or the use of TRACS features, please contact our office. We are here to help ensure a smooth transition to full HOTMA compliance.