Extension of the HOTMA
Implementation Deadline
to 1/1/2027

Today, HUD posted HSG Notice 2025-07 announcing a new HOTMA implementation deadline of 1/1/2027. 

Owner/agents may continue to use current Pre-HOTMA rules to process resident certifications. Many of RBD OnDemand training classes include instruction for HUD Multifamily Housing programs (MFH) without HOTMA changes. 

HUD guidance on HUD’s HOTMA web site indicates that owner/agents may implement certain portions of HOTMA as long as the tenant file is documented to include:

1. Which HOTMA and other provisions included in HSG Notice 2023-10 were implemented;
2. How the family’s income, assets, and mandatory deductions were determined under the implemented HOTMA provisions; and
3. If applicable, what the tenant rent would have been under the pre-HOTMA rules, and the HOTMA tenant rent amount that was entered using the “rent override” function.

We have created a Note to File (NTF) template, available on our RBD HOTMA Resources Page, that may help you document the file if you have implemented HOTMA changes.

Please note that, even though mandatory HOTMA implementation has been delayed, owner/agents must develop and maintain a Pre-HOTMA Tenant Selection Plan and a HOTMA compliant Tenant Selection Plan. Owner/agents will not implement the HOTMA compliant Tenant Selection Plan until HOTMA compliant software is available. Owner/agents must also develop and maintain a Pre-HOTMA EIV Policy and a HOTMA compliant EIV Policy. Owner/agents will not implement the HOTMA compliant EIV Policy until HOTMA compliant software is available. The deadline for completing these two HOTMA compliant policies was 5/31/2024. These policies are subject to review during the Management & Occupancy Review. 

Check out our RBD FASTForms for TSP Templates and EIV Policy Templates. Our FASTForms library has been updated to include Pre-HOTMA and HOTMA compliant forms. All RBD FASTForms packages included both Pre-HOTMA and HOTMA versions of policies and supporting forms.