HUD Postpones HOTMA Final Implementation Deadline for MFH Programs 

In an earlier HUDBlast, we told you that HUD released HSG Notice 2023-10 Implementation Guidance: Sections 102 and 104 of the Housing Opportunity Through Modernization Act of 2016 (HOTMA). You can access the notice from HUD’s MFH/HOTMA page by clicking HERE.  

HUD recognizes that HOTMA includes significant program and system changes that owner/agents and families need time to understand and implement. While the HOTMA effective date is still January 1, 2024, HUD has established a new deadline for full implementation of January 1, 2025. This means that

  1. 0.3.A compatible software must be implemented before 12/31/2024; and
  2. Certifications with an effective date of 1/1/2025 or later MUST comply with new HOTMA requirements.  

This gives industry stakeholders a little more time to seek HUD clarifications related to:

  • Certain aspects of the Notice including optional start dates for specific changes;
  • Policy Updates (TSP, EIV, etc.);
  • Section 8 Asset Restrictions based on whether or not a family owns real property suitable for occupancy that a member has the right to sell, and, the Net Cash Value Of a Family’s Included Assets exceeds $100,000.00.
  • Interim Recertification - Specifically the introduction of the new Non-Interim Recertification. 

Owner/agents should be aware that there are various milestones throughout the year – for example, EIV policies and TSPs must be updated no later than 3/31/2024.  

Many of the changes introduced through HOTMA require software updates. HUD is in the process of finalizing software requirements that will be incorporated into TRACS version 2.0.3.A. Once HUD publishes software requirements, software vendors are tasked with software development and testing. Release of new CA or site software that is compliant with 2.0.3.A should occur in 2024. 

Many of the changes driven by site software - such as the change to “calculation of income from assets” - are not required until site software has been updated…Whew!  

HUD has informally clarified that 2024 certifications created using the current 202D rules will not require correction. 

So, bottom line? You’ve got some “breathing room”. 

Throughout the next couple of weeks, we’ll be posting updated information about HOTMA requirements on our HOTMA Resources Page.  

Our HOTMA FASTForms are being edited now and will be available again as soon as the updates are completed. For those of you who have already purchased the HOTMA FASTForms, updates will be sent to you automatically at no charge.