HUD CPD has extended the mandatory compliance date for its programs with HOTMA to January 1, 2027, following similar recent extensions for other HUD programs. The Notice says, "CPD grantees may continue to set their own compliance dates as early as January 1, 2024, but must be in full compliance no later than the date established by this document."

Which programs? PD programs involved include HOME, HOME-ARP, the NHTF, HOPWA, CDBG, ESG, Continuum of Care (CoC) programs, and CPD programs funded through competitive processes (Competitive Programs). 

Why? The stated purpose of this action is to allow additional time for HUD to finalize necessary system updates and for CPD grantees to fully incorporate the new income and asset requirements into their programs.

Why won't this matter for many HOME or NHTF properties? Note that this extends the DEADLINE.  However, many HOME and NHTF Agencies have already implemented HOTMA.

• Unlike HUD Multifamily Housing (MFH) and Public and Indian Housing (PIH) programs, there are no public-facing HUD software, extensive mandated forms, or other systems required for CPD properties to implement HOTMA. In light of the significant benefits of HOTMA to the low-income residents they serve, owners/agents, and the monitoring agencies themselves, many HOME and other program monitors have allowed or required owners/agents to comply with HOTMA already.
• Surveys indicate that up to 95% of state agencies will have implemented HOTMA for LIHTC purposes by 1/01/2026. Also doing so for HOME and the NHTF, which are often combined with tax credits, makes logistical sense.

Even if HOTMA is not implemented fully by an agency, what is allowed? HUD is permitting CPD grantees the choice to implement certain componts of HOTMA before the rest, if they choose. This includes: 

• Applicable HOTMA income safe harbors in 24 CFR 5.609(c)(3). This is otherwise known as using the income determinations of family income from "other means-tested programs" (federal TANF, Medicaid, SNAP, the LIHTC, a local PHA providing a voucher, among others).
• Additionally, HUD is permitting HOME PJs the choice to implement all expanded income safe harbors and flexibilities described in the HOME 2025 Final Rule [24 CFR 92.203] without implementing the remaining provisions of the regulations updated by the HOTMA final rule. Among other things, this includes using the family income determinations of state and local public assistance similar to the federal programs allowed by HOTMA, and asset self-certification when assets do not exceed the annual imputed asset threshold. 

Read the Notice on the Federal Register website HERE 

Almost all LIHTC and HOME/NHTF agencies, and Rural Development have converted to HOTMA at this point.

Details:

• Legally, the HOTMA change to regulation was effective 1/01/2024.
•  The HUD Section 8 PBRA and other MFH programs deadline was also recently extended to 1/01/2027. See HUD MFH Notice 2025-07.
• Rural Development converted in July of 2025.
• LIHTC implementation is entirely up to each state LIHTC agency. Surveys indicate that about 95% of agencies will have implemented HOTMA by 1/01/2026.