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HOTMA Compliance Updates – as of 9/22/25

We have received information from many Housing Finance Agencies (HFAs) about their plans to implement the Housing Opportunity Through Modernization Act (HOTMA) for the Low-Income Housing Tax Credit (LIHTC) program. Below, you will find the status of states that have either confirmed in writing or discussed adoption of HOTMA. We will continue to update this information as we learn more. It is important to note that this information is subject to change, even for states that are currently marked as ‘Confirmed.’ 

Please note, some states have released new Tenant Income Certifications to update the passbook rate, however, if additional HOTMA guidance or instruction has not been released those HFAs will not appear on the list below. 

State/Territory  HOTMA Adoption Status  Additional Notes 
NCSHA  Confirmed  As of August 28th, 2024, NCSHA has released model forms. Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins. 
Alabama  Confirmed  In September of 2024, Alabama confirmed they will be moving forward with the NCSHA TIC. 
Alaska  Confirmed  On April 12th, 2024, AHFC stated that “all Programs are required to implement these changes no later than September 1, 2024. While implementation is required, no noncompliance will be identified until January 1, 2025, to allow Owners, Partners, and Manager’s time to complete training, update internal policies and procedures, and complete implementation.” 
Arizona  Confirmed  On June 3rd, 2025, Arizona extended the HOTMA compliance date to 01/01/2026 following HUD Guidance. 
Arkansas  Confirmed  ADFA has released a TIC that has minor edits to the NCSHA TIC. AFDA released a draft Affordable Housing Compliance Manual that includes HOTMA guidance with a thirty-day comment period. ADFA is expected to be releasing new HOTMA forms mid-September. AFDA is mandating the implementation of HOTMA to align with HUD effective 01/01/2026, but will permit early implementation.    
California  Confirmed  CTCAC has announced that implementation will not be mandatory effective January 1, 2026. CTCAC’s monitoring guidance for HOTMA policies is available to projects that opt to implement the new policies beginning January 1, 2024. Implementation can be partial or full implementation. Income and asset documentation shall be collected within 120 days of January 1, 2026.   Please note that CTCAC has added new fields to the TIC related to assets which will require an update to Voyager Affordable plug-ins. 
Connecticut  Confirmed  On 09/24/2024 Spectrum updated their website to use the NCSHA TIC.   Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins. 
Colorado  Confirmed  On 06/24/2024 CHFA released an updated manual and HOTMA compliant Tenant Income Certification. On 07/14/2025 CHFA decided to extend the mandatory implementation date of HOTMA to January 1, 2026, for the Housing Tax Credit and CHFA multifamily loan programs. CHFA strongly encourages HOTMA implementation sooner when possible for all Housing Tax Credit and CHFA Loan developments not layered with Section 8, HOME, or comparable programs. Prior to January 1, 2026, noncompliance findings will not be issued for HOTMA-related tenant file errors during Program Compliance reviews. Instead, the Program Compliance Officer (PCO) will issue observations. 
Delaware  Confirmed    On 01/04/2024 Spectrum Compliance website for DE was updated with a HOTMA updated Tenant Income Certification. Delaware has pushed back mandatory compliance to 01/01/2026 to align with HUD. 
Georgia  Confirmed    DCA has announced a HOTMA effective date of 01/01/2024, with a compliance date for implementation will be no later than January 1st of 2025.  This delay allows property managers and management companies additional time to update systems (i.e., software, staff, forms, etc.) for the upcoming implementation.  Property managers/management companies will not be penalized for HOTMA-related errors until the compliance deadline (January 1st, 2025). GDCA announced on 06/17/2025 that it will provide a grace period through December 31, 2025. 
Hawaii  Confirmed  On December 12, 2023, HHFDC held an affordable program training led by Spectrum Compliance which included HOTMA regulation showing an effective date of 01/01/2024.   In 09/2024 Spectrum posted a new HOTMA compliant TIC which has now been programmed. 
Idaho  Confirmed  IHFA has posted a new HOTMA-compliant TIC.   Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins. 
Illinois  Confirmed  On 09/10/2024 IHDA released new forms for HOTMA including a TIC, with an implementation effective 01/01/2025. 
Indiana  Confirmed  IHDCA has updated forms for HOTMA on April 1st, 2024, including a HOTMA TIC.   IHCDA will make findings for HOTMA related noncompliance in 2024 and will require necessary corrective action. However, IHCDA will not impose penalties for HOTMA specific issues during calendar year 2024 or impose fines for items specifically linked to HOTMA changes. 
Iowa  Confirmed  IFA has posted a new HOTMA-compliant TIC (almost identical to NCSHA’s version), Compliance Manual for LIHTC, HOME, and NHTF, and HOTMA-compliant forms.   Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins. 
Kansas  Confirmed  On November 10th, 2023, Kansas Housing released an updated TIC and compliance manual draft, confirming they will adopt HOTMA on January 1, 2024. 
Kentucky  Confirmed  In December 2023 KHC issued HOTMA Guidance and an updated TIC. The guidance state “Changes should be implemented for all households moving in or recertifying after January 1, 2024.” Since HUD delayed HOTMA implementation, KHC will not be taking enforcement actions for any HOTMA file deficiency prior to January 1, 2026. 
Louisiana  Confirmed  Louisiana has provided a HOTMA TIC (similar to NCSHA’s version) and previously announced implementation of HOTMA effective for January 1st, 2025, move-ins and annual recertifications with an effective date of April 1, 2025. Currently LHC is not requiring HOTMA, but does allow implementation at the property level.   Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins. 
Maine  Confirmed but documentation not released  Maine confirmed in Asset Management Notice #2024-01 10 that the compliance deadline was extended to July 1, 2025guidance will be coming soon. An effective date of 01/01/2024 has been set, but January 1st, 2025, is the compliance deadline. No HOTMA TIC has been released. 
Maryland  Confirmed  Maryland acknowledged HUD’s extension to 1/1/2026 and has recommended the use of the NCSHA TIC for HOTMA compliance. The Department will extend the interim guidance established in Multifamily Notice 24-01 until the new implementation date of 1/1/2026. 
Massachusetts  Confirmed  In 09/2024 Spectrum updated their website with a new HOTMA compliant TIC. Most recent published guidance was released in March 2024. 
Michigan  Confirmed  MSHDA released a new memo and HOTMA TIC on January 3rd, 2024, with guidance that states “MSHDA is looking to have all HOTMA changes implemented by 1/8/2024 for any certifications completed on or after that date.” 
Minnesota  Confirmed but documentation not released  Minnesota Housing Finance Agency’s (MHFA) Housing Tax Credit Compliance Guide states that for certifications and recertifications effective on or after July 1, 2025, or such later date determined by HUD when the Housing Opportunities Through Modernization Act (HOTMA) must be fully implemented. Per the HUD delay, HOTMA implementation will not be mandatory until for certifications effective January 1, 2026. Affordable Housing Connections has delivered a new TIC but have now confirmed they are now awaiting more guidance from HUD.MHFA and sub-allocator Affordable Housing Connection (AHC) have confirmed that sites are permitted to the NCSHA TIC for their HOME, National Housing Trust Funds, MARIF, HOPWA, and Housing Tax Credits programs. 
Mississippi  Confirmed      MHC has posted a new HOTMA compliant TIC as of 09/2024. MHC allowed implementation of HOTMA as of 6/1/2024, but does not currently have a final implementation date. 
Missouri  Confirmed  On November 20th, 2023, Missouri Housing Development Commission published an updated TIC and HOTMA Manual to adopt HOTMA as of January 1, 2024. 
Montana  Confirmed  Montana Housing provided an updated copy of their TIC on 10/08/2024. 
Nevada  Confirmed  Nevada Housing Division has stated that the agency is monitoring for HOTMA regulations, but are not currently reporting any findings. Nevada Housing Division will align to HUD’s deadline of January 1, 2026.   NHD has released a HOTMA TIC, which has now been programmed. 
New Hampshire  Confirmed but documentation not released  On April 10th, 2025 New Hampshire released a memo with arequiring HOTMA effective date ofto be implemented starting on 01/01/2026. This memo stated that the NH Housing TIC will be discontinued and a Tenant Income Certification (TIC) produced by the owner/agent’s software or other HOTMA compliant TIC should be used. 
New Jersey  Confirmed  New Jersey has stated that HOTMA changes should be implemented by January 1st, 2026. In Developer Bulleting 2025 #14 the agency stated New Jerseyit is in the process of updating their HOTMA policies and that previous guidance was to be disregarded until further notice.   Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins. 
New York 
(HCR) 		 Confirmed  HOTMA guidance was released in a memo dated 12/9/24. On 6/2/25 the agency updated their memo to reflect that they will implement their HOTMA policies effective1/1/26.   Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins. 
New York 
(HDC) 		 Confirmed  HDC has released a new TIC and their 2025 Marketing Handbook FAQ states that recerts effective 7/1/2025 and later should be fully compliant with the new forms and HOTMA rules and that the agencies will continue to accept both old and new forms for recerts effective in April, May, and June. 
North Carolina  Confirmed  The North Carolina Housing Finance Agency announced during their Compliance 101 Training in April 2025 a delay in their HOTMA implementation until 7/1/2025. An updated TIC was posted on NCHFA’s website on 07/24/2024. 
North Dakota  Confirmed  NDHFA will note HOTMA related non-compliance issues identified in calendar year 2024 and will require necessary corrective action. However, NDHFA will not impose penalties or HOTMA specific issues during calendar year 2024- i.e. will not issue 8823s for items specifically linked to HOTMA changes. As of 10/2024, North Dakota has adopted the NCSHA TIC. Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins. 
Ohio  Confirmed  On September 26th, 2024, Ohio revised their timeline in response to HUD’s announcement stating “OHFA will implement HOTMA on January 1, 2025, however, mandatory use of HOTMA rules will only be applicable for initial tenant certifications and recertifications effective May 1, 2025, onward.”    As of 5/5/2025, OHFA released its HOTMA-compliant Tenant Income Certification (TIC). All certifications effective 5/1/2025 or later must meet HOTMA requirements. Tenant events entered into DevCo before 5/5/2025 must be re-entered using the new TIC format, as data from the previous version does not transfer.   Per OHFA’s guidance issued on 7/23/2025, owners/management agents should not print or have tenants sign the re-entered HOTMA TIC solely for format alignment. Instead, a clarification record must be placed in the tenant file explaining the re-entry was due to the TIC update.   If the HOTMA TIC was printed and signed before the 7/23/2025 guidance, it is considered an error. A clarification record must state it was signed prior to OHFA’s updated instructions. 
Oklahoma  Confirmed  On December 18th, 2024, OHFA announced that the HOTMA implementation date would be January 1, 2025. The agency’s website has been updated with new HOTMA forms.   Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins. 
Oregon  Confirmed    Oregon plans to fully implement HOTMA and begin monitoring under HOTMA guidelines effective January 1, 2025; however, from January 1, 2025, through June 30, 2025, findings specific to new HOTMA requirements will be documented as “observations.”   Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins. 
Pennsylvania  Confirmed    Pennsylvania Housing Finance Agency (PHFA) announced during their training that they are adopting (HOTMA) and are developing a new Tenant Income Certification (TIC) form. PHFA’s HOTMA implementation date will be 7/1/2025. PHFA published updated HOTMA guidance on 78/2912/2025. 
Rhode Island  Confirmed  On 10/04/2024 Rhode Island confirmed they will be adopting the NCSHA TIC. Rhode Island’s HOTMA implementation date will be 7/1/20251/1/2026.   Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins. 
South Carolina  Confirmed  South Carolina Finance and Development Authority confirmed in July 2024 that HOTMA will be implemented effective October 1, 2024; however, the HOTMA policy will not be enforced until January 1, 2025. On 08/28/2024 confirmed they will be adopting the NCSHA TIC. Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins.    
South Dakota  Confirmed  As of October 2024, South Dakota Housing Development Authority published HOTMA guidance, and a HOTMA compliant TIC was posted in November 2024.  SDHDA confirmed that HOTMA compliance would be mandatory effective July 1, 2025.   Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins. 
Tennessee  Confirmed  THDA announced that all HOTMA changes as described should be implemented or begin on January 1, 2025. Pre-planned actions with an effective date of January 1, 2025, through April 30, 2025, such as annual recertifications, will be subject to phased-in considerations.   Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins. 
Texas  Confirmed  Texas Department of Housing and Community Affairs stated during a training session that they will begin conducting audits for HOTMA starting on January 1, 2024. 
Utah  Confirmed  UHC has released a new TIC and Under $50k form. UHC Guidance from memo on March 12th, 2024: “UHC will not enforce HOTMA-related file errors (i.e., will not issue 8823’s) discovered prior to January 1, 2025.”   On September 19, 2025 UHC released the updated Compliance Manual that includes important updates related to HOTMA. The agency also released revised and new forms on their website. 
Vermont  Confirmed  Vermont has released a HOTMA compliant TIC using the NCSHA template and announced a HOTMA compliance date of 07/01/2025.   Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins. 
Virginia  Confirmed  Virginia Housing has released a new TIC effective January 1st, 2024.   As of 10/18/2024 the agency has delayed mandatory compliance with HOTMA. HOTMA compliance will be required for all tenant income certifications by July 1, 2025, or the date required for all programs by HUD or the IRS. 
Washington  Confirmed  On January 9th, 2025 WSHFC released a new HOTMA compliance TIC. Washington has stated that HOTMA changes should be implemented by January 1st, 2025.   
West Virginia  Confirmed  On 01/04/2024 Spectrum Compliance website for WV was updated with a HOTMA updated Tenant Income Certification. 
Wisconsin  Confirmed  HOTMA compliant TIC was released 04/05/2024 and this document is now available. Guidance from WHEDA: “The effective date for HOTMA implementation in Housing Tax Credit (HTC), aka Low-Income Housing Tax Credit (LIHTC), and WHEDA Financed Properties is 01/01/2024. However, some changes may be delayed due to pending updates by major software vendors.” 
Wyoming  Confirmed  WDCA has posted a HOTMA compliant TIC and confirmed that they are targeting 01/01/2026 for an implementation date. A new HOTMA manual will was be released later this yearin August 2025 on WCDA’s website. 

In addition to tracking Housing Finance Agencies, we are closely monitoring HUD’s HOTMA resource page and newsletters, along with RHS resources and training, for updates related to all HUD multifamily programs and Rural Development. 

Agency  HOTMA Adoption Status  Additional Notes 
HUD  Confirmed but documentation not released    On May 29th, 2025, HUD extended the HOTMA implementation deadline to January 1, 2026.   On September 17, 2025 HUD published in the Federal Register a 30-day notice of proposed information collection for the Owner’s Certification with HUD Tenant Eligibility and Rent Procedures, this includes the revised HUD-50059, HUD-50059 Instructions, HUD-50059-A, HUD-50059-A, Instructions, HUD-9887/9887-A, HUD-27061-H, HUD-92236, HUD-90100, HUD-90101, HUD-90102, HUD-90104, HUD-90105-a, HUD-90105-b, HUD-90105-c, HUD-90105-d, HUD-90106, HUD-90011 (Enterprise Income Verification (EIV) System Multifamily Housing Coordinator Access Authorization Form), HUD-90012 (Enterprise Income Verification (EIV) System User Access Authorization Form), EIV and You Brochure, Resident Rights and Responsibilities Brochure, and Fact Sheet for HUD Assisted Residents. HUD has updated the requirement for Tenant Selection Plan and EIV policies and procedures to be completed May 31, 2024. In January April 2025, updated versions of VAWA 5380 and 5382 were posted. Due to some uncertainty and the removal of supporting documents on HUDclipsHUDCLIPS, Yardi is awaiting further guidance from HUD to update our standard forms accordingly. As of November 2024, we are awaiting HUD forms for review.   On 09/20/2024 HUD provided Notice H 2024-09 which extended the compliance date of HOTMA to July 1, 2025. HUD has updated the requirement for Tenant Selection Plan and EIV policies and procedures to be completed May 31, 2024. 
HOME 
HTF 
HOPWA 
CDBG 
ESG 
CoC CPD 		 Confirmed but documentation not released  On December 31th, 2024, HUD they are extending the compliance date for the HOME Investment Partnerships Program (‘‘HOME’’), HOME-American Rescue Plan program, Housing Trust Fund (‘‘HTF’’), Housing Opportunities for Persons With AIDS (‘‘HOPWA’’), Community Development Block Grant Program (‘‘CDBG’’), Emergency Solution Grants (ESG), Continuum of Care (CoC) programs, and CPD programs funded through competitive process (‘‘CPD programs’’) until January 1, 2026.   Please note: In certain situations, housing finance agencies oversee the HOME program. Therefore, timelines and expectations should be confirmed with them separately. 
RHS  Confirmed    To align with HUD, RHS Multifamily Housing is extending full implementation of applicable HOTMA regulations until July 1, 2025. All MFH tenant certifications effective on or after July 1st, 2025, must comply with HOTMA requirements. On 06/13/2024, RHS Multifamily Housing published an updated CHAPTER 6:  Project Occupancy to outline new tenant eligibility requirements. 

Based on the considerable number of local programs and the limited guidance available, we are unable to track their status regarding HOTMA. 

Voyager clients: For more details, please log into Client Central and review the recorded webinars available under Product Resources -> Video Library -> Filter on Affordable. 

Breeze clients:  For more details, please log into Breeze and review Help Center -> Instructional Webinars. 

RightSource clients: For more details, please log into RightSource Help and review the new HOTMA section. 

For additional information regarding HOTMA please visit: 

  • HUD’s Multifamily HOTMA Resources 
  • https://www.hud.gov/hud-partners/multifamily-hotmahttps://www.hud.gov/program_offices/housing/mfh/hotma 
  • National Center for Housing Management 
  • NCSHA