On May 29, HUD published Notice H-2025-03, which extends the compliance date for Sections 102 and 104 of the Housing Opportunity Through Modernization Act of 2016 (HOTMA) to January 1, 2026, for Multifamily Housing (MFH) programs. Previously, MFH owners were expected to comply with Sections 102 and 104 by July 1, 2025. This delay aligns HOTMA compliance dates for both MFH and Community Planning and Development (CPD) programs.
For HAs operating programs under HUD’s Public and Indian Housing (PIH) office—including public housing and Housing Choice Vouchers—the Department has not yet established a HOTMA compliance date. However, HUD is requiring agencies to implement three provisions of the HOTMA final rule (income exclusions, income definitions, and de minimis errors) in PIH programs by July 1, 2025. More information on those provisions is available in a previous edition of the Advocate.
Since publication of the final HOTMA rule in February 2023, PHADA has advocated for HAs and owners to have sufficient time to implement these significant changes and for HUD to modernize its IT systems before mandating compliance. The Association will continue to press for additional compliance deferrals as neither TRACS 203B nor the Housing Information Portal has been fully developed or sufficiently tested.