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A PBCA’s Guide to HOTMA
About HOTMA
HOTMA, signed into law on July 29, 2016, is a federal act intended to update and streamline processes and reduce burdens on housing providers in various HUD programs, including Multifamily Housing. It introduced changes to how income and assets are calculated and reviewed for individuals receiving federal housing assistance.
What does all that mean for owners, management agents, and tenants??
Spoiler alert: it’s a good thing! The goal of HOTMA is to streamline and modernize the process of calculating income and assets in Section 8 housing. While we understand that learning new rules can be daunting, it’s important to keep in mind that the end result should be an easier process for everyone.
What are some ways that HOTMA will streamline and modernize HUD programs?
- Fewer Interim Recertifications! With the new regulations, an Interim Recertification is only processed when a tenants income goes up or down by 10% or more.
- Less signatures needed on paperwork! With the new regulations, tenants only need to sign the HUD-9887 one time.
- Easier verifications! With the new regulations, managers can use income verification from other federal benefits programs, such as SNAP or TANF.
What are Sections 102, 103, & 104?
These refer to the sections of the HOTMA law.
- Section 102 – Income & asset calculations
- Section 103 – Not applicable to Multifamily housing
- Section 104 – Eligibility & asset caps
While the law itself passed in 2016, it was quite a complex process to translate the legislative mandates in HOTMA into practical regulations that could be implemented across various HUD programs. After extensive public comment periods, including a proposed rule in 2019 and a reopened comment period in 2020, HUD finally published the final rule in February 2023. This final rule officially implemented key sections of HOTMA, specifically Sections 102, 103, and 104, which affect regulations found in 24 CFR Part 5 and 24 CFR Part 891.
As you may have heard, HUD has published a deadline for owners and management agents to comply with HOTMA regulations. (Currently the deadline is January 1, 2027.) However, this isn’t as cut and dry as it sounds.
Currently, HUD is working to update many important forms (like the HUD-50059) and computer systems (like TRACS). These updates are necessary for owners and management agents to fully implement the new HOTMA regulations.
While HUD is working on updating those forms and systems, owners and management agents can implement some HOTMA regulations, but not all HOTMA regulations. Please see the HOTMA Status Update section below for examples of what can and cannot be implemented.
HOTMA Status
Last updated September 17, 2025
Download a printable version of this section here.
Examples of HOTMA items that cannot be implemented now.
Many HOTMA changes are waiting for TRACS 203A, the new HUD-50059, and the new HUD Model Lease to be published before Owner/Agent’s can implement them.
- Non-necessary personal property
Requires entering a code on the new HUD-50059 to indicate the type of asset. - Interim Reporting Requirements
Requires the new HUD Model Lease, which will indicate the new interim reporting requirements. - Not processing an Interim Recertification for all income changes
Requires the new HUD Model Lease, which will indicate the new interim reporting requirements. - $100,000 Asset Cap
Requires TRACS 203A to be released and fully implemented at the property.
Examples of HOTMA items that must be ready but not implemented.
Owner/Agents must have a revised version of these documents with HOTMA policies included. However, the revised versions of the documents must not be implemented yet.
- EIV Policies and Procedures
Create a version of this document that includes all HOTMA changes. Do not implement the HOTMA version until TRACS 203A, the new HUD-50059, and the new HUD Model Lease are available. - Tenant Selection Plan (TSP)
Create a version of this document that includes all HOTMA changes. Do not implement the HOTMA version until TRACS 203A, the new HUD-50059, and the new HUD Model Lease are available.
Examples of HOTMA items that can be implemented now.
If an Owner/Agent chooses to implement a new policy, it must be applied to all subsidized tenants equally. All tenant files must clearly indicate the date when new policies are applied. We also recommend O/A’s keep record in their TSP of the date when a new policy becomes effective, to have a clear record of why applicants may have been processed differently throughout the years.
- Utilizing Safe Harbor Verification as third-party verification of income.
- Utilizing two paystubs instead of six to verify income.
- Utilizing the current balance for checking accounts
instead of the 6-month average. - Utilizing a Social Security award letter dated within 12 months,
instead of 120 days, to calculate income. - Accepting self-certification of assets under $50,000.
HUD Guidance
We’ve gathered up a list of the most important HUD resources for understanding HOTMA.
- Housing Opportunity Through Modernization Act of 2016
- Federal Register: HOTMA Implementation (2/14/23)
- Federal Register: Updated List of Exclusions from Income (1/31/24)
- HUD Housing Notice H 2024-09: Revised Compliance Date (9/20/24)
- HUD Housing Notice H 2023-10: Implementation Guidance (9/29/23)
- HUD Housing Notice H 2024-04: TSP & EIV Policy Deadline (2/28/24)
- HUD Multifamily: HOTMA Information Page
- HUD Multifamily: Use of Rent Override and Documenting Tenant Files
- HUD Multifamily: List of Discretionary Policies to Implement HOTMA
- HUD Multifamily: Q&A for Multifamily Programs (2/2024)
Did we miss anything? Please let us know if there are any additional HUD resources to add to this list!
Webinar Q&A
On August 26, 2025 CMS hosted a webinar on implementing HOTMA rules and guidance t which a number of important questions were raised by attendees. Our HOTMA experts have answered each of those questions and published them below as a useful resource for anyone looking for more information on how HOTMA may impact them.
Continuing Support
HOTMA has brought about changes adjustments to our work here at CMS, too! As a Performance Based Contract Administrator, we are we working to learn the new HOTMA regulations so that we can ensure compliance. But more importantly, we are also helping owners and management agents navigate the transition to the new HOTMA landscape.
CMS is in a unique position to provide owners and management agents with training and technical assistance to help translate the new HOTMA regulations into real world processes. Our goal is to share information and guidance issued by HUD regarding HOTMA implementation, and to address questions and concerns we are hearing from the owners and management agents across the country.
We want to help owners understand how to adapt their processes and systems to not only ensure compliance, but to get the full benefit of the streamlined rules in the HOTMA regulations.
HOTMA Resources
Use the search bar below to find worksheets, checklists, instructions and other HOTMA related resources.
