On May 29, 2025 HUD issued HUD Notice 2025-03 extending the compliance date for the Housing Opportunity through Modernization Act (HOTMA) of 2016 particularly Sections 102 and 104. to January 1, 2026. Specifically, this relates to the updated income and assets documentation requirements for income certifications.
The notice reads as follows,
The purpose of this Notice is to extend the HOTMA final rule compliance date to January 1, 2026. This Notice supersedes Notice H 2024–09, which extended the date by which Owners must comply fully with Sections 102 and 104 of the Housing Opportunity Through Modernization Act of 2016 (HOTMA) final rule until July 1, 2025. … 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. Thereafter, HUD published Notice H 2024–09 that extended the January 1, 2025 deadline to July 1, 2025. This Notice however extends the compliance date to January 1, 2026. The requirement applies to Owners participating in the programs listed in section 4 (Applicability) of Notice H 2023–10.
This does not directly apply to LIHTC, HOME, or USDA/RD properties. Each funding program and their associated monitoring agencies determine the HOTMA compliance date. In some cases, state agencies have already implemented HOMTA or are planning to move forward with the July 1, 2025 compliance date without further delay.
