On December 31, HUD announced a delayed compliance date for Sections 102 and 104 of the Housing Opportunity Through Modernization Act of 2016 (HOTMA) for programs administered through its Community Planning and Development (CPD) office. The new HOTMA compliance date for CPD programs is January 1, 2026, though grantees may choose to implement HOTMA provisions before that date if they are ready to do so.
The notice applies to the following programs:
- HOME Investment Partnerships (HOME) and HOME-American Rescue Plan (HOME-ARP).
- Community Development Block Grant (CDBG).
- Housing Trust Fund (HTF).
- Housing Opportunities for Persons with AIDS (HOPWA).
- Emergency Solutions Grants (ESG).
- Continuum of Care (CoC).
In general, CPD grantees are expected to implement all HOTMA Sections 102 and 104 at the same time before January 1, 2026. However, the Department is allowing HOPWA, HOME, and HTF grantees to begin using ‘safe harbor’ income verification policies prior to implementing other HOTMA rules. Interested parties should consult the Federal Register (linked above) for more details.
With this publication, HOTMA Sections 102 and 104 compliance dates for HUD programs are currently the following: