On December 17, 2025, HUD published Notice HA 2025-07, which defers the compliance date for Sections 102 and 104 of the Housing Opportunity through Modernization Act of 2016 (HOTMA) for Multifamily Housing owners to January 1, 2027. Previously, the HOTMA compliance date had been January 1, 2026—only 2 weeks after the notice was published and at a time when most January 1 recertifications had already been completed.
HUD still has several milestones to reach before Multifamily owners can comply with HOTMA Sections 102 and 104. It has yet to publish final versions of HOTMA-compliant forms, such as the 50059 income certification form. The Department has also not updated TRACS to the 203A standard, and the current version of TRACS cannot accept HOTMA-compliant income certifications.
PHADA will continue to advocate for the Department to defer HOTMA compliance until the necessary forms and technology upgrades are in place and both HAs and Multifamily owners have sufficient time to acclimatize to them. The Association will keep members updated regarding the latest HOTMA news through the Advocate, Breaking News, and social media.