HOTMA is the biggest change to how HUD counts income and assets in a generation, and it has been moving so slowly that a lot of operators stopped tracking where it stands. That is a mistake. The rules are settled. Only the deadline keeps moving, and when it lands, every certification you run has to follow the new math.
What HOTMA is
The Housing Opportunity Through Modernization Act was signed into law in 2016. HUD published the final rule putting Sections 102 and 104 into effect in February 2023, and that rule became effective on January 1, 2024. Section 102 changes how income is defined and reduces how often you have to review it. Section 104 sets asset limits, and adds deductions and exceptions for things like retirement savings.
Where the deadline actually stands
This is the part that trips people up. The full compliance date for HUD Multifamily owners has been pushed back more than once. It went from January 1, 2025, to July 1, 2025, to January 1, 2026, and the most recent HUD notice moved it again to January 1, 2027. Public Housing and Housing Choice Voucher timelines sit with HUD's Office of Public and Indian Housing and have run on their own delayed track.
One thing that is easy to miss: HOTMA does not directly apply to LIHTC, HOME, or USDA Rural Development properties. Each of those programs and their monitoring agencies set their own compliance date, and some state agencies moved earlier than HUD did. If you run a mixed portfolio, you cannot assume one date covers all of it. You have to confirm the date for each program and each agency you answer to.
The changes that matter most
- The imputed asset threshold jumped from 5,000 dollars to 50,000 dollars. Below the new threshold, you no longer impute income on assets the same way, and self-certification is allowed in more cases.
- There is a net family asset cap. The statutory 100,000 dollar figure is adjusted for inflation, and the current adjusted number is 105,574 dollars. Important nuance: owners have discretion in how they apply the asset limitation at annual recertification. You are not required to evict a household for crossing it.
- Checking accounts now use the current balance. The old six month average requirement is gone. The cash value of a checking account is simply its current balance.
- The Earned Income Disregard sunset. No new families qualified after the rule took effect, and the benefit phased out fully on January 1, 2026.
- Income reviews happen less often. Section 102 changes the thresholds that trigger interim reexaminations, which is meant to cut paperwork for both staff and residents.
What to do before the date lands
Three things. First, update your Tenant Selection Plan and your EIV policies to match the new rules, because those documents are where an auditor looks first. Second, train the staff who actually run certifications, since the income and asset math is where errors will show up as findings. Third, confirm the real compliance date for every program in your portfolio, not just the Multifamily one in the headlines.
Owners who want to adopt early can, by calculating income and rent under HOTMA manually and using the rent override function in the current version of TRACS until the updated TRACS release is out. That path works, but it puts the burden on getting the new calculations right by hand, every file, every time.
Where this gets operational
The risk with HOTMA is not the concept, it is the consistency. New thresholds, new asset rules, and updated policy documents only help if every certification actually follows them. The Access runs recerts and compliance from your own approved documents, so the rule you wrote into your plan is the rule that gets applied to the file, instead of living in a binder while staff work from memory.
This is an operations summary, not legal advice. The rules, notices, thresholds, and dates described here are set by HUD and other agencies and they change. Confirm the current requirements against the official notices and with your compliance team or counsel before you rely on them.