As of Jan. 1, HUD updated the inflation-adjusted asset thresholds under the Housing Opportunity Through Modernization Act (HOTMA), reshaping how income, asset limits, and deductions are treated for households across various HUD-assisted housing programs. While the core compliance rules remain the same, it’s important to understand that the timeline for enforcement now differs depending on the housing program.

For Public Housing and Housing Choice Voucher (HCV) programs, certain HOTMA provisions, which include new income exclusions, definitions, and asset treatment rules, were required as of July 1 with no further delays. By contrast, HUD has formally extended the compliance deadline for Multifamily Housing programs, including Section 8 PBRA, Section 202, and Section 811, until Jan. 1, 2026. This six-month extension gives owners and agents of Multifamily properties time to update software systems, revise certification procedures, and align their Tenant Selection Plans and EIV protocols with the full HOTMA implementation.

We’ll focus on how HUD’s new 2025 asset thresholds, which are $103,200 for eligibility and $51,600 for self-certification and imputed income, apply to tenant certification and eligibility under HOTMA. While Multifamily owners have until 2026 to fully comply, understanding the structure of these rules now will ensure smoother onboarding, more accurate recertifications, and readiness for both Management and Occupancy Reviews (MORs) and HUD audits in the coming year.

NOTE: We published a clarification of owners' enforcement options in our September 2025 issue here.

Eligibility Ceiling on Household Assets

One of the most significant 2025 updates is the cap on net family assets for eligibility, now set at $103,200. For Public Housing and Section 8 programs, a household that exceeds this cap is no longer eligible to remain in the program. This change introduces a bright-line limit where previously there was more flexibility. For most owners of HUD-assisted Multifamily properties, this means that if a household discloses or accumulates assets above this ceiling, continued participation in the program may no longer be possible unless the household can demonstrate that certain assets are excluded under HUD’s rules.

Owners should be aware that the $103,200 eligibility limit must be monitored at key certification points. If a household’s assets increase beyond this amount during tenancy, recertification may render them ineligible unless the assets fall into excluded categories, such as necessary personal property or certain retirement accounts. For example, a household that receives an inheritance of undeveloped land valued at $110,000 would likely be found over-income unless that land is excluded from net family assets, which is something that would depend on its use and income status.

Streamlined Self-Certification for Households Below $51,600

When it comes to verifying assets, HOTMA allows a simplified path for households whose total net family assets fall at or below $51,600. In these cases, families may self-certify both the value of their assets and the income those assets are expected to produce. 

Managers and owners can accept these certifications without collecting supporting documentation for that recertification year. This is intended to reduce the paperwork burden on both the household and site staff for lower-asset tenants. That said, full third-party asset verification is still required at least once every three years for all households, regardless of their asset level.

For example, a typical household might self-certify that they have a $2,500 savings account; a $1,200 checking balance; and a vehicle used for commuting valued at $7,000. These would be reported with expected income of $25 in annual interest on the certification form. The owner would retain the form in the tenant file and defer full asset verification until the three-year window requires it.

If a household’s total assets exceed $51,600, however, the simplified route is no longer available. In those cases, owners must revert to traditional documentation methods such as bank statements, investment records, and other proofs of ownership and income. This threshold is not a one-time consideration. It must be evaluated at each annual or interim certification to determine whether self-certification is appropriate for that year.

Counting or Excluding Non-Necessary Personal Property

HUD has also clarified how non-necessary personal property such as luxury items, investment accounts, or collectibles is treated in the asset calculation. For 2025, if the total value of a household’s non-necessary personal property is at or below $51,600, these items are excluded entirely from the net family asset total and are treated as having zero value for rent and eligibility purposes. But if the combined value of these non-essential assets exceeds the threshold, the full amount must be included in the asset calculation, not just the amount above the limit.

This can be a nuanced determination. Necessary personal property such as furniture, vehicles required for daily use, or assistive devices is excluded regardless of value. But assets like a vacation boat, a jewelry collection, or a second car that isn't essential may fall into the non-necessary category. Owners and agents must be diligent in making fact-based decisions about what qualifies as necessary versus non-necessary, since that categorization can have a material effect on whether a household’s total assets remain below or rise above the relevant thresholds.

For example, a household might report owning a classic car valued at $18,000; a home entertainment system worth $4,000; and a collectible guitar appraised at $7,000. If the combined value of these items falls under $51,600, they are excluded entirely. However, if the guitar’s appraisal comes in higher than expected and pushes the total above the threshold, all three items must be fully included in the net asset calculation. Owners should document these determinations, especially when the classification isn't obvious.

Imputed Income Now Reserved for Higher-Asset Households

A major procedural shift involves when owners must impute income from assets. Under earlier rules, owners had to estimate and impute asset income any time a household’s assets exceeded $5,000. As of 2025, that trigger point has increased to $51,600. Now, if a household’s total net family assets remain at or below that threshold, there’s no need to impute any income. You would include in the rent calculation only the actual, documented income from the assets.

But if total net family assets exceed the $51,600 level, then asset income must be imputed but only for specific assets where income cannot otherwise be determined. For example, a bank account with no interest earnings is simply counted as producing zero income; nothing is imputed. But if a household owns a vacant parcel of land with no rental history and no way to estimate its income potential, HUD expects the owner to apply its current passbook savings rate, which is set at 0.45 percent for 2025. This approach limits unnecessary imputing of income from assets while ensuring that high-value but non-income-producing assets don’t go completely uncounted.

Consider a household with $65,000 in net family assets, including $25,000 in investment accounts with $1,200 in actual earnings, and $15,000 in vacant land generating no income. Because the total assets exceed $51,600, and the land’s income can't be determined, the owner must impute income on just that $15,000 portion. Applying the 0.45 percent passbook savings rate results in $67.50 in imputed income, which is then added to the $1,200 in actual investment income for a total of $1,267.50 in annual asset income.

Another subtle but important shift is that imputed income is now calculated only on the individual asset that lacks determinable income and not on the household’s entire portfolio. This prevents overestimating income for households whose holdings may be sizable but transparent.

What These Changes Mean During Certification

What makes the new HOTMA framework both powerful and challenging is that these thresholds interact. A household with net assets under $51,600 can take advantage of self-certification, avoid the inclusion of certain personal property, and skip asset income imputation entirely. But once assets move beyond that line, the rules change in a cascading way. The simplified procedures fall away, and owners must begin counting excluded property, obtaining verification, and imputing income on any hard-to-value assets.

These rules mean that owners may need to update how they handle move-ins and annual recertifications. Staff might also need some retraining to know what questions to ask when a household’s assets are close to the limits. 

It’s also more important than ever to keep clear records, especially when a tenant says their property is “necessary” or when it’s unclear whether asset income should be counted or estimated. If you’re getting ready for a Management and Occupancy Review, the new HOTMA asset rules might mean fewer issues related to verifying small asset amounts. But HUD will still expect clear records showing why a household was allowed to self-certify and how any excluded assets were reviewed. Make sure you can show that you’ve kept up with the threshold changes and that your staff understands how to apply them.

NOTE: We published a clarification of owners' enforcement options in our September 2025 issue here.