January 2024 ARs & HOTMA – HUD’s Multifamily Housing Programs

We’re at the end of August, preparing the 1st reminder Notices for January 1, 2024 ARs and HUD has yet to issue guidance explaining requirements for implementation of HOTMA for the Multifamily Housing Industry.  

These changes are relatively complex and HUD is taking the necessary time to consider these changes and the effect on the industry.  This is essential to successful implementation of HOTMA.  

In absence of such guidance, and in hopes that HUD recognizes owner/agents' attempts to be “as compliant as possible”, I am providing suggestions about what property managers can and cannot do to implement as many HOTMA provisions as possible. 

While HUD’s Public and Indian Housing Division has extended deadlines for the implementation of HOTMA, no such delay has been announced for Multifamily Housing.  

We have posted a list detailing suggested treatment of changes explaining what can be implemented now and what has to be implemented later even though HUD has not officially announced a delay for multifamily housing. However, absent software updates and new forms, there is only so much industry stakeholders can do. See our HOTMA Resources Page and click on RBD HOTMA Delayed Rollout. Additional information is provided on our News page.