On Thursday, May 29, 2025, HUD announced that HOTMA implementation would be further delayed until January 1, 2026 for programs covered by the HUD Multifamily Housing (MFH) program. NCHM and others anticipated the delay, primarily due to the lack of infrastructure in place to fulfill HOTMA’s obligations. As of now, there are no HUD Model Leases to uphold certain provisions of the law (such as Interim Reexamination requirements and policies surrounding the new asset limitations); there is no updated 50059 to capture new data required; there are a few HUD forms still missing HOTMA-related language; and certification transmission systems (TRACS 203A) are not fully deployed.
We will continue to update our clients as we receive more information from HUD. For now, continue to follow the boundaries of your prevailing TSPs, EIV Policies & Procedures, and leases, and certify your tenants with pre-HOTMA rules. If you have chosen to implement HOTMA early via the rent override feature (MFH programs), you may continue to do so.