HUD has released draft TRACS 203A Monthly Activity Transmission (MAT) Guide materials for stakeholder review.

HUD is specifically asking the industry to comment.

Comments are due October 2, 2026.

That may be the most important point right now.

TRACS 203A has been anticipated for years and is now the release through which HUD plans to accommodate HOTMA-related certification and reporting requirements that TRACS 202D cannot fully support.

HUD currently requires Multifamily Housing owners to fully comply with HOTMA beginning January 1, 2027, while TRACS 202D remains the current production version.

The draft 203A materials give us a much better look at how HUD expects HOTMA to work not simply as policy, but in actual tenant certifications, HUD-50059 reporting, and TRACS.

But these documents are still draft guidance, and that distinction matters.

HUD is also clear that the HOTMA provisions associated with TRACS 203A cannot be implemented through 203A until the release and related documents are officially published.

Why the comment period matters

Our focus here is the compliance and operational side, not MAT programming.

Even from that perspective, however, the draft is revealing.

It begins to connect the HOTMA rules we have been teaching for several years with the certification and reporting processes owners and management agents will actually have to use.

Our review is still underway, so we are not treating every provision in the draft as settled. We have already identified several areas that deserve careful comparison with HUD's existing HOTMA guidance.

Some may simply be drafting or technical issues. Others may need policy clarification.

That is exactly why the comment period matters.

One small example with a very practical consequence

Consider assets disposed of for less than fair market value.

For many years, HUD Handbook 4350.3 supplied a practical administrative rule: owners generally did not have to count dispositions unless the aggregate amount exceeded a $1,000 threshold during the preceding two years.

Importantly, that $1,000 amount was not contained in the old Part 5 regulation itself. HUD used the Handbook to create a practical threshold for administering the rule.

HUD's current HOTMA implementation guidance does not state that $1,000 threshold, and the draft 203A materials likewise do not appear to restore it. Applicable assets disposed of for less than fair market value during the preceding two years are instead reported as divested assets.

That creates an interesting practical question: how small is too small to matter?

Give $200 to an adult child? Potentially a divested asset.

Make modest charitable gifts? Potentially divested assets.

Give $20 in cash to someone on the street who needs it? Read literally, there does not appear to be a minimum threshold simply because the amount is trivial.

This is hardly the most consequential issue in HOTMA, and owners can certainly administer the rule as written. But the old $1,000 threshold provided a practical boundary. Without one, very small transactions can technically remain relevant for two years even though many families may never think to report them. This creates potential inconsistencies that the old threshold practically eliminated. 

Whether HUD ultimately provides some practical minimum threshold or additional clarification remains to be seen.

It is a small example, but a useful one. The draft MAT Guide is beginning to show how HOTMA will operate in actual certifications—and sometimes the operational details raise questions that are difficult to see from the regulation alone.

There is much more in the 203A package

Our first review shows that the draft materials address, among other things:

• HOTMA interim recertification requirements and family-composition changes;
• Safe Harbor income determinations;
• the substantially revised HOTMA asset rules and income from assets;
• the HOTMA asset limitation applicable to Section 8 PBRA and Section 202/8;
• family members versus other household members, including foster children and foster adults;
• health and medical care, attendant care and auxiliary apparatus, and child care expense deductions and hardship provisions;
• annually adjusted HOTMA amounts; and
• the information needed to distinguish certifications completed under the old rules from certifications completed under HOTMA.

In some places, 203A provides the data and reporting structure needed for rules we already know.

In others, the implementation details help show how HUD expects those rules to operate in practice.

And some provisions may still need clarification before the Guide becomes final.

This is the time to comment

HUD has established a stakeholder comment period ending October 2, 2026.

How to submit comments

Deadline: October 2, 2026 Email: [email protected] Subject line: Draft 203A MAT Guide Comments/Your Organization

Where possible, identify the specific MAT Guide chapter or section and page involved.

Software vendors will understandably be examining the technical specifications closely.

But owners, management agents, Contract Administrators, compliance professionals, trainers, and others who have to administer these requirements should also be looking closely at the practical results.

You do not have to be a MAT expert to recognize when an instruction produces an unusual or undesirable compliance outcome.

That perspective belongs in the comment process too.

More to come

We are continuing our review of the draft 203A materials against the HOTMA Final Rule and HUD's current Multifamily HOTMA guidance.

This first look is deliberately not a definitive interpretation of the new MAT Guide. It is not final, and there are areas that deserve more evaluation.

But we know this much:

The industry has until October 2 to help HUD get it right.

We will share additional observations as our review continues.