On September 20, 2024, HUD published a HUD Notice 2024-09 that changes the date by which Multifamily Housing (MFH) Owners must be in full compliance with the HOTMA Section 102 and 104 final rule.
Section 6.2 of Notice H 2023–10 requires Multifamily Housing Owners to be in full compliance with the HOTMA final rule and HUD’s updated income and asset documentation requirements for income certifications having an effective date on or after January 1, 2025. … The compliance date stated in section 6.2 of Notice H 2023–10 is hereby revised from January 1, 2025, to July 1, 2025.
The MFH delay comes just days after HUD’s Office of Public and Indian Housing announced that public housing and the Housing Choice Voucher program will also not be required to comply with HOTMA Section 102 and 104 income and assets provisions by January 1, 2025. This excludes Earned Income Disregard (EID) provisions.
Implementation for MFH Delayed Before
On September 29, 2023, HUD issued a notice providing guidance to Public Housing Agencies (PHAs) and Multifamily Housing (MFH) owners regarding the implementation of the many program changes brought about by HOTMA. The changes were made to sections 102 and 104 of HOTMA and the final rule, issued by HUD on February 14, 2023.
At that time, the deadline for implementation and full compliance had been moved up a year to January 1, 2025. Owners and PHAs who were ready for HOTMA could opt to put the changes into effect as soon as January 1, 2024.
HUD Programs Affected by HOTMA
- Housing Choice Voucher (HCV)
- Public Housing
- Section 8 Moderate Rehabilitation (Mod Rehab)
- Section 8 Moderate Rehabilitation Single Room Occupancy (SRO)
- Section 8 Project-Based Rental Assistance (PBRA)
- Section 202/8
- Section 202/811 Capital Advance with Project Rental Assistance Contracts (202/811 PRAC)
- Non-insured 236 projects with Interest Reduction Payments (236 IRP)
- Section 811 Project Rental Assistance (811 PRA)
- Senior Preservation Rental Assistance Contracts (SPRAC)