HOTMA implementation rolled out in phases, with compliance dates set — and in places extended — by HUD notice. Because the dates moved more than once, many properties are unsure what's enforceable now. Here's how to establish your position.
The structure of the rollout
HUD implemented HOTMA's income, asset, and recertification provisions through rulemaking followed by program-specific notices setting compliance dates for multifamily, public housing, and voucher programs — with software readiness (including TRACS updates for multifamily) driving several extensions.
What you must have regardless of date debates
- Updated policies — Tenant Selection Plan, EIV policy, recertification policies reflecting HOTMA
- Updated forms and worksheets — old imputation and exclusion logic retired
- Software configured to current requirements
- Staff trained on the new calculations — the rules changed under veteran muscle memory, which is where errors concentrate
How to confirm your current obligation
Don't rely on secondhand summaries: check the most recent HUD notice for your program type, your software vendor's compliance bulletins, and your contract administrator's guidance. Compliance dates are notice-driven and program-specific — verify against the current notice rather than assuming last year's answer still holds.
The practical standard reviewers apply
Whatever the letter of the current deadline, reviewers are already testing files against HOTMA expectations. A property still running pre-HOTMA logic today is accumulating findings, not saving effort.
Need the current status confirmed for your program? 59AI answers implementation questions with citations to the governing notice — $19.99/month.
FAQ
Is HOTMA fully in effect? Core income/asset provisions have compliance dates behind us for most programs; verify your specific program's current notice for any remaining phase-ins.
We haven't updated our TSP — how bad is that? Policy documents are among the first things reviewers pull. Update before your next review, not after.
59AI's accredited HOTMA courses get whole teams to the current standard.