HOTMA Resources
| HUD HSG Notice 2023-10 HUD released this Notice on 9/29/2023 and then released again on 2/5/2024. The notice provides clarification regarding implementation of the HOTMA. |
| HOTMA Final Rule |
| EIV & TSP Discretionary Policies Owner/agents may use this table to identify HOTMA Discretionary Policies and to help make decisions about which options to implement. Turn on “Protection” to make this form fillable. |
| HOTMA TSP Checklist Updated 9/3/2024 Based on information provided on HUD's multifamily housing HOTMA website, and based on other occupancy updates, we have compiled a checklist of TSP requirements, including HOTMA requirements that must be incorporated no later than May 31, 2024. Please note, this checklist is subject to change at any time with the release of new HUD guidance. |
| HOTMA TSP Checkup Class Questions & Answers Consolidated class questions and answers from the 1.5 hour Online Training Workshop session that took place on Tuesday, May 21, 2024. Responses provided are based on our understanding of HUD's guidance as it relates to HOTMA and HUD's Multifamily Housing Programs. |
| HOTMA EIV Policy Checklist Updated 9/3/2024 Based on information provided on HUD's multifamily housing HOTMA website, and based on other occupancy updates, we have compiled a checklist of changes to your EIV Policy that must be incorporated no later than May 31, 2024. Please note, this checklist is subject to change at any time with the release of new HUD guidance. |
| HOTMA Today 2024 Class Questions & Answers After three nine hour sessions held at the beginning of 2024, we consolidated class questions and provided responses based on our understanding of HUD’s guidance related to HOTMA and HUD’s Multifamily Housing Programs. Updated 10/2024. |
| AVAILABLE TRAINING |
| Who Needs HOTMA Training? Property Owner/Agents, Property Managers, Compliance Teams, Contract Administrators, Software Developers, Software Vendors and Software Support Staff |
| RBD OnDemand Training - HOTMA - Multifamily Housing On February 14, 2023, HUD Released the Final Rule - announcing the long-awaited implementation of The Housing Opportunity Through Modernization Act (HOTMA). On September 29, 2023, HUD Released HSG Notice 2023-10 Implementation Guidance: Sections 102 and 104 of the Housing Opportunity Through Modernization Act of 2016 (HOTMA) providing additional guidance. On February 5, 2024, HSG Notice 2023-10 was replaced with a modified HOTMA Notice. HOTMA introduces changes to eligibility, income inclusions and exclusions, verification, calculation of adjusted income, treatment of assets and much more. Owner/agents must wait until software updates are released in order to implement new calculations and new eligibility rules. Join Mary for a high-level explanation of how this changes requirements for HUD’s Multifamily Housing programs. This class was updated in October 2024. |
| RBD OnDemand Training - Streamlined Verification & Implementation of the FAST Act HOTMA incorporates Streamlined Certification, Streamlined Verification of Assets, and Streamlined Verification of Fixed Income. These changes were introduced in 2016 and 2018 and simplify verification. While preparing to implement HOTMA, we strongly recommend that owner/agents, and other industry stakeholders, become familiar with Streamlined processes. This class provides detailed information about each of these three changes. |
| HOTMA RBD FASTFACTS |
| RBD FASTFacts - Streamlining & the FAST Act with HOTMA Streamlined Determination of Income, Streamlined Verification of Assets Valued at $51,600 or less and Streamlined Certification simplify the Annual Recertification Process. These options were introduced in 2016 and 2018 but have been modified with the implementat of HOTMA (effective when HOTMA compliant site software is available and implemented). This FASTFact provides a detailed explanation of each process. Owner/agents should note that they may implement none, one, two or all of the Streamlining options. |
| RBD FASTFacts - Section 8 Asset Restrictions – Real Property Suitable for Occupancy - HOTMA This document provides a summary of HUD’s new Section 8 Asset Restriction specifically related to the Real Property Rule. For HUD’s Multifamily Housing programs, the Section 8 Real Property Rule restricts assistance for new families who own Real Property Suitable for Occupancy. Owner/agents may choose to enforce this restriction when completing Annual and Interim Recertifications for existing assisted residents. |
| RBD FASTFacts - HUD Verification with HOTMA Changes This FASTFact explains new verification options and requirements under HOTMA. These changes will become effective when HOTMA compliant site software is available and implemented. If owner/agents implemented any of these changes, a Note to File must be included in the applicant/tenant file. |
| RBD FASTFacts - HOTMA Change to IR For HUD’s Multifamily Housing programs, Interim Recertification requirements change significantly under HOTMA. This FASTFact provides a summary of mandatory and optional changes that may be implemented when new leases are available and executed and when HOTMA compliant site software is available and implemented. If any changes are implemented, a Note to File explaining which new rule was used must be included with the certification in the tenant file. RBD strongly recommends that owner/agents wait to implement changes to Interim Recertification until HOTMA compliant site software has been implemented. |
| RBD FASTFacts - Section 8 Asset Restrictions – New with HOTMA For HUD’s Section 8 programs, HOTMA introduces new Asset Restrictions related to the Net Cash Value of Included Assets (Asset Cap) and the ownership of Real Property Suitable for Occupancy (Real Property Rule). This FASTFact provides a summary of the rules and suggestions for describing these rules in your Tenant Selection Plan and/or House Rules. Section 8 Asset Restrictions must not be applied until new HUD leases have been released (by HUD) and executed. Release of new HUD leases is expected to coincide with the release of HOTMA compliant software (TRACS v 2.0.3.A). |
| HOTMA Forms |
| Note to File HOTMA Rules HOTMA. Note to File. When owner/agents implement HOTMA rules prior to the implementation of HOTMA compliant site software, the owner/agent must make a note to the file explaining which HOTMA changes have been implemented. This document can be edited to standardize any Note to the Tenant File explaining which HOTMA rules were implemented before HOTMA compliant site software was available/implemented. |
| Note To File for HOTMA Changes Implemented Before 203A Site Software It is a HUD requirement to document the file when HOTMA changes are implemented HOTMA compliant site software is available or implemented. This document allows owner/agents to create a standard Note to File (NTF) explaining which HOTMA changes have been implemented. This allows for a standard note for all tenant files and eliminates the need for site/certification staff to insert handwritten notes. |
| RBD HOTMA Rules and Program Type Updated 4/2/24 Some owner/agents are looking for a list of HOTMA rules and how they apply to each contract type. While most HOTMA changes affect all Multifamily Housing programs, this list provides a breakdown by Program Type. |
| RBD HOTMA Implementation Checklist Updated 9/5/2024 This checklist, created by RBD, provides a summary of tasks necessary to successfully implement changes introduced by HOTMA. This checklist is based on our interpretation of HUD instruction or clarifications provided as of the revision date of this document. Please note, revised versions may be posted as HUD continues to provide clarification. |
| RBD HOTMA Implementation Deadlines Updated 9/5/2024 Many owner/agents are trying to decide when to implement specific HOTMA changes. This table includes our recommendations (updated 8/13/2024). Currently, owner/agents do not have to incorporate any HOTMA changes until site software is updated to support TRACS v 2.0.3.A and HOTMA. |
| RBD Income Inclusions and Exclusions – HOTMA Updated 9/11/2024 Please note that formal HUD guidance only includes a list of income exclusions. This list, created by RBD, provides a list of inclusions and exclusions based on our interpretation of changes introduced via the HOTMA Final Rule. Changes to income inclusions and exclusions are implemented starting with certifications effective when HOTMA compliant site software is available and implemented. This version of our list is based on our interpretation of HUD instruction or clarifications provided as of the revision date of this document. Please note, revised versions may be posted as HUD continues to provide clarification. |
| HOTMA Treatment of Assets Updated 9/10/2024 Please note that this document was created based on our interpretation of HUD’s HOTMA guidance related to assets provided in HSG Notice 2023-10. Changes to asset inclusions and exclusions may be implemented starting with certifications effective when HOTMA compliant site software is available and implemented. This version of our list is based on our interpretation of HUD instruction or clarifications provided as of the revision date of this document. Please note, revised versions may be posted as HUD continues to provide clarification. |
| Medical Expense HOTMA With the implementation of HOTMA, The handling of the Medical Expense Deduction (now called Health & Medical Expense Deduction) has changed. HUD now refers owner/agents to IRS resources to determine whether a Medical Expense should be included or excluded. In an effort to create a more comprehensive policy and to ensure that residents are treated in a fair and equitable manner, we created an unofficial list of medical expenses including some guidance on how these medical expenses may be treated when determining the medical expense deduction for qualified families. If HUD provides guidance in any of the known HUD resources or clarifications, we use HUD guidance. If HUD is silent, we consider guidance provided by the IRS and attempt to incorporate HUD rules. In the FASTFact Medical Expenses – HOTMA, we explain the Health & Medical Expense Deduction requirements that owner/agents must implement starting with certifications effective when HOTMA compliant site software is available and implemented. |
| AVAILABLE RESOURCES |
| HUD’s Multifamily Housing Resource Page https://www.hud.gov/program_offices/housing/mfh/hotma |
| HUD’s email for questions related to HOTMA and it’s impact on HUD’s Multifamily Housing programs. MFH_HOTMA@hud.gov |
| HUD’s one-page summary of the key HOTMA changes to Multifamily Housing programs Updated 2/5/2024 https://www.hud.gov/sites/dfiles/Housing/documents/HOTMA_One_pager.pdf |
