HOTMA Compliance Updates – as of 6/12/24

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Please note this information is updated often.

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 but documentation not released Many HFAs have stated they’re awaiting updated forms to be released from NCSHA.   NCSHA is currently gathering feedback and is slated to release model forms in July of 2024. 
Alabama Confirmed but awaiting agency clarification On April 12, 2024 the agency sent a memo stating they will be implementing HOTMA effective 1/1/2025. Owners/management may start complying with the HOTMA regulations anytime this year.  AFDA has confirmed their forms will likely change with NCSHA model forms, and therefore we are currently holding on programming of documents in this state. 
Alaska Confirmed  On April 12, 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 01/10/2024 ADOH released a HOTMA impacted TIC, and has stated “(ADOH) strongly encourages Owners/Agents to prepare now for the HOTMA implementation that will start Jan. 1, 2024, and continue until the full compliance deadline of January 1, 2025.” 
Arkansas Confirmed but documentation not released ADFA has released a TIC that is partially updated with passbook rate, and $50,000 on assets. Confirmed with ADFA that they are working on guidance and HOTMA need not be implemented until 01/01/2025.   
California Confirmed but documentation not released “Monitoring guidance for these changes will be as follows and will go into effect on January 1, 2024. These provisions cannot be used in 2023 to certify households that will have eligibility as of January 1, 2024.”  CTCAC has yet to release a new Tenant Income Certification. 
Connecticut Confirmed  On 01/04/2024 Spectrum Compliance website for CT was updated with a HOTMA updated Tenant Income Certification. 
Delaware Confirmed   On 01/04/2024 Spectrum Compliance website for DE was updated with a HOTMA updated Tenant Income Certification. 
Georgia Confirmed but awaiting agency clarification  DCA has made available a suggested HOTMA compliant Tenant Income certification, (TIC) for properties to use and we have reached out to Georgia DCA for clarification on this document.  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).  
Hawaii Confirmed On December 12, 2023, HHFDC held an affordable program training lead by Spectrum Compliance which included HOTMA regulation showing an effective date of 01/01/2024.  On 01/04/2024 Spectrum Compliance website for HI was updated with a HOTMA updated Tenant Income Certification. 
Indiana Confirmed  IHDCA has updated forms for HOTMA on April 1, 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 but documentation not released On September 26, 2023, Iowa Finance Authority sent an email announcing they will be adopting HOTMA. Iowa has not released a new TIC. 
Kansas Confirmed On November 10, 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.” 
Maine Confirmed but documentation not released Maine confirmed in Asset Management Notice #2024-01 that guidance 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 yet. 
Maryland Confirmed but documentation not released Maryland LIHTC properties may elect to follow pre-HOTMA standards during 2024.  Properties may adopt HOTMA within sixty (60) days of the property’s software being ready for implementation. No TIC has been publicly released. 
Massachusetts Confirmed On 01/04/2024 Spectrum Compliance website for MA was updated with a HOTMA updated Tenant Income Certification. 
Michigan Confirmed MSHDA released a new memo and HOTMA TIC on January 3, 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 Affordable Housing Connections has delivered a new TIC but has now confirmed they’re now awaiting more guidance from HUD. Minnesota Housing Finance Agency (MHFA) has not released guidance on the implementation of HOTMA. 
Missouri Confirmed On November 20, 2023, Missouri Housing Development Commission published an updated TIC and HOTMA Manual to adopt HOTMA as of January 1, 2024. 
Nevada Confirmed by documentation not released Nevada Housing Division has stated that “HOTMA’s program updates are effective January 1, 2024, and are mandated to be fully compliant January 1, 2025. During this transitioning period properties should try to be “as compliant as possible”. NHD will notate errors during audits completed in 2024 and corrective action should be taken. The HOTMA errors notated in 2024 will not be reported.”  Nevada has not released a new TIC with HOTMA changes. 
New Hampshire Confirmed but documentation not released On December 5th, 2023, Section 8 and Section 811 properties must follow HUD MFH guidance on HOTMA implementation; however, at this time, New Hampshire Housing is recommending that all other properties hold off on HOTMA implementation until guidance is received. 
New Jersey Confirmed but documentation not released New Jersey has stated that HOTMA changes should be implemented by January 1st, 2025. No HOTMA compliant TIC has been released. 
North Carolina Confirmed but documentation not released The North Carolina Housing Finance Agency has recently posted a fact sheet on their website announcing for HOTMA is in effect for January 1, 2024 move-ins and annual recertifications with an effective date of April 1, 2024. They have not yet posted a new HOTMA compliant TIC. 
Ohio Confirmed but documentation not released On 04/11/2024 OHFA confirmed the agency will be implementing HOTMA effective 1/1/2025. If an Owner/Management agent decides to implement all of the HOTMA rules prior to January 1, 2025, an OHFA clarification record must be placed in the tenant file stating certification was conducted using HOTMA rules. No HOTMA compliant TIC has been released. 
Oklahoma Confirmed by documentation not released On December 13, 2023, Oklahoma Housing Finance Agency provided a newsletter stating ”Over the next year, OHFA will be updating our program guidelines, including policies, procedures, and internal systems, and conduct software updates to implement HOPWA across our Housing Development Programs. Once updated, OHFA will sponsor a training for all owners/managers on the new implementation and guidance for HOTMA.” This included a note that all must comply with HOTMA final rule no later than 01/01/2025. 
Pennsylvania Confirmed but documentation not released  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 has published some resources on their website, but has not released a new TIC. 
South Carolina Confirmed but documentation not released South Carolina Finance and Development Authority confirmed in a newsletter “Any updates to SC Housings policies and procedures with regard to the Housing Opportunity Through Modernization Act (HOTMA) will begin October 1, 2024. More information will be released when updates are finalized.” 
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.”  
Virginia Confirmed  Virginia Housing has released a new TIC effective January 1, 2024. All properties in the Virginia Housing rental portfolio must prepare for and implement the HOTMA eligibility criteria for all tenant income certifications by January 1, 2025, or the date required for all programs by HUD or the IRS. Properties that choose not to implement HOTMA criteria for new certifications after January 1, 2024, will receive an administrative comment in the property audit about the required HOTMA Compliance Deadline. 
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.” 

 
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  In February 2024 HUD released updated supplemental guidance to address outstanding questions regarding the HOTMA final rule affecting the TRACS 203A migration. We are still waiting on updated HUD forms such as the 50059 and HUD Model Leases as well as an updated MAT guide. 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 8th, 2023, HUD announced in Federal Register/Vol. 88, No. 235 that 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, 2025. 
RHS Confirmed but documentation not released  Like HUD, we are awaiting updated forms and guidance for the Rural Development program. It was announced in a training in November of 2023, that a new 3560-8 will be released by 01/01/2024 and RHS has set a target date of 06/01/2024 for the new deduction amounts and medical percentage thresholds to be in place.  RHS also posted a memorandum in February 2024 that provided the program specific administrator exceptions from HOTMA. 

 
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 
  • National Center for Housing Management 
  • NCSHA 
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