On September 4, 2024, the Rural Housing Service (RHS) Office of Multifamily Housing (MFH) published an Unnumbered Letter (UL) notifying MFH staff of the anticipated timeline for implementing the requirements of the Housing Opportunity Through Modernization Act (HOTMA). The HOTMA changes that impact the determination of income affect the RHS Multifamily Housing portfolio.
RHS will implement HOTMA on January 1, 2025. The implementation timeline includes updates for software providers, publication of updated forms, and system updates by January 1, 2025.
Changes due to HOTMA involve new income calculations, adjustments to deductions, relief based on income thresholds, and changes in verification processes.
Asset and income changes cover imputed income calculations for personal property assets, consideration of actual and imputed income from assets, and inclusion of real property as a net family asset.
Exclusions and exceptions mention retirement accounts excluded from net family assets and specific HUD regulations not implemented by RD.
Childcare hardship exemption permits households to continue receiving childcare expense deductions under specific circumstances for up to 90 days.
The UL provides guidance on the changes in tenant income and asset calculations due to HOTMA, a timeline for upcoming changes related to HOTMA, exceptions for implementation, and details on the delayed implementation until January 1, 2025.
It also outlines specific updates, such as new income calculations, deductions, relief mechanisms, verification processes, and changes in asset calculations. Additionally, it clarifies the sections of HOTMA that will and will not be implemented by RD and provides details on training for staff and property managers.
All operators of RD rental housing should obtain a copy of the UL and review it carefully for requirements that will be in place in less than four months. Within the next few days, I will post an article on the AJJCS website providing details on the UL.