HOTMA Compliance Delayed for MFH Programs

The new compliance deadline is July 1, 2025.

HUD has issued Notice H 2024-09 delaying HOTMA for Multifamily Housing programs. The previous deadline to come into compliance that came from the most recent version of HUD Notice H 2023-10 was Jan. 1, 2025. Now, the new compliance deadline is July 1, 2025.

HOTMA is a major rule change in affordable housing impacting property procedures, tenant income, and eligibility calculations. On HUD’s end, it has experienced delays in finalizing software specifications, key forms, and training materials. The delay in implementation tools or resources means that owners aren’t able to move forward with implementation.

Another issue has been the confusion related to HOTMA implementation at LIHTC sites. Various state housing agencies have approached the tax credit-applicable portions of HOTMA on a different implementation timeline than HUD has and this has not only deepened confusion but also resulted in sites with mixed subsidies finding themselves out of compliance with one of their regulating entities. The implementation delay may give HUD a chance to work with the Treasury Department and state housing agencies to establish an aligned implementation schedule for HOTMA that would apply to both HUD-assisted and LIHTC sites, and to issue clear requirements for layered-subsidy properties.