On September 2, 2026, HUD’s Office of Multifamily Housing Programs posted the draft TRACS Release 203A Monthly Activity Transmission (MAT) Guide for stakeholder review and comment on its website.
For anyone tracking the pace of HOTMA implementation in multifamily housing, this is worth stopping on. Not because it signals HOTMA is finally arriving, but because of what it suggests about how much work remains before it can.
What HUD Actually Posted
The draft MAT Guide covers the changes needed to implement the Housing Opportunity Through Modernization Act (HOTMA) within TRACS for multifamily programs, including updated 203A instructions, adjustment calculations, tenant rent calculations, imputed income proration, non-citizen rule proration, and a full set of supporting chapters and appendices. This is the technical backbone HUD needs in place before multifamily owners and agents can process HOTMA-compliant certifications through TRACS.
HUD is opening a 30-day comment period that closes on October 2, 2026. Comments should be sent to MATGuideComments@hud.gov, ideally with a specific chapter, section, and page number.
One clarification: HOTMA implementation is being carried out separately by two different HUD offices. The Office of Multifamily Housing (MF) covers project-based Section 8 and other insured or assisted multifamily properties, and implements HOTMA through TRACS and documents like the MAT Guide. The Office of Public and Indian Housing (PIH) oversees Public Housing Agencies, with its own systems, separate guidance, and OMB information-collection process. What follows here is specifically about MF. It shouldn’t be read as a statement about where PIH and PHAs stand in their own HOTMA implementation.
A Notable Line
Buried in the notification is a line worth flagging:
HOTMA provisions associated with TRACS Release 203A cannot be implemented until the corresponding TRACS release and related documents have been officially published by HUD.
Publishing a draft for comment is not the same as going live, and the TRACS release itself must still occur separately after this document is finalized. A comment window that closes October 2 is only the start of that process: comments have to be reviewed, revisions made, the guide finalized, and then the TRACS release itself built, tested, and deployed against that finalized guide.
It’s Not the Only Piece Still in Process
The MAT Guide isn’t the only HOTMA-related document sitting in a pre-release state. The HUD Model Lease and related lease addenda remain under Office of Management and Budget (OMB) review, and HUD has indicated it will not review or approve owner-created HOTMA lease addenda until that OMB approval is in place. That matters operationally because once the model lease is released, owners and agents implementing it must give families at least 60 days’ notice before the end of their lease term, along with a clear explanation of the modification and the family’s options to accept or refuse it. A late release of the model lease reduces the runway owners’ need to meet the 60-day requirement before the mandatory compliance date.
Taken together, the draft MAT Guide still in comment and the model lease still awaiting OMB approval point to the same conclusion: several of the foundational documents multifamily HOTMA compliance depends on are still moving through federal review, not finalized, and in the field.
The mandatory compliance date for multifamily programs remains January 1, 2027, as established by Notice H 2025-07. HUD has acknowledged that this date is currently under evaluation. Any change to it, however, would have to come through a published Notice; it isn’t something that shifts informally. Until HUD issues one, January 1, 2027, stands as the compliance date owners and agents should be planning against, even as the documents underlying it are still in draft.