Article | Update on LIHTC HOTMA Implementation

"Several Steps Down the Road" | Update on LIHTC Implementation

Excerpt from the Course Achieve HOTMA Success: LIHTC, HOME, and NHTF Edition

Since the first module of our HOTMA hybrid LIHTC course was filmed, HUD has made several adjustments to the required implementation date. State LIHTC agencies have responded to these deadline adjustments in different ways. Although the legal HOTMA implementation date was 1/01/2024, HUD realized it was not ready to implement as that date approached. HUD's TRACs 203A software was not working and owner/agent software could not be designed to work with 203A. Additionally, HUD Model Leases and forms were not ready. In response, HUD extended the date to come into compliance to 1/01/2025. When compliance was still not possible toward the end of 2024, HUD moved the "into compliance" date to 7/01/2025. Per HUD's instructions, once an owner can get into compliance, HUD will begin to monitor for HOTMA, but only issue observations, not findings, during Management Occupancy Reviews (MOR).

With this history in mind and the difference between the legal compliance date and HUD's subsequent allowances to "come into compliance" later, state LIHTC agencies have responded in seven different ways.  Below is a table of the options and what owners/agents must do to comply.

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