The Housing Opportunity Through Modernization Act of 2016 (HOTMA) introduced important reforms to income and asset determination in HUD-assisted housing programs. Sections 102 and 104 specifically targeted Public Housing and Section 8 programs, aiming to streamline processes and enhance efficiency. Section 102 focused on income reviews, while Section 104 set asset limits for applicants and participants.
Originally, HUD set a compliance deadline of January 1, 2025, for owners to implement these changes. However, this deadline was later extended to July 1, 2025. On May 29, 2025, HUD issued Notice H 2025–03, which pushes the compliance date to January 1, 2026. This new extension applies to all multifamily owners participating in the affected programs.
This additional time provides owners with the opportunity to complete necessary system updates and ensure full compliance with HOTMA requirements.
The updated compliance date applies to the following programs:
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Housing Choice Voucher (HCV)
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Public Housing
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Section 8 Moderate Rehabilitation (Mod Rehab)
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Section 8 Moderate Rehabilitation Single Room Occupancy (SRO)
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Section 8 Project-Based Rental Assistance (PBRA)
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Section 202/8 (202/8)
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Section 202/162 Project Assistance Contract (202/162 PAC)
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Section 202/811 Capital Advance with Project Rental Assistance Contracts (202/811 PRAC)
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Non-insured 236 projects with Interest Reduction Payments (236 IRP)
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Section 811 Project Rental Assistance (811 PRA)
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Senior Preservation Rental Assistance Contracts (SPRAC)
For more detailed information, stakeholders can refer to the official HUD notice at: https://www.hud.gov/sites/dfiles/OCHCO/documents/hsgN-25-03.pdf.
For any questions or further clarification, multifamily housing owners are encouraged to contact HUD at MFH_HOTMA@hud.gov.
Stay Up-to-Date with HOTMA Compliance
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