On November 2, 2026, the U.S. Department of Housing and Urban Development (HUD) issued Notice H-2026-07, extending full compliance with Sections 102 and 104 of the Housing Opportunity Through Modernization Act (HOTMA) to January 1, 2028, for HUD Multifamily Housing programs. Counting from the original January 1, 2025 date, this is the fourth extension, and it leaves compliance teams with the same question as the last three: what should we do with this?
The short answer: For HUD Multifamily properties, stay on your current procedures and hold major HOTMA changes until HUD finalizes its forms and system specifications. For every other program in your portfolio, confirm the date that applies, because several did not move.
We asked Corbin du Mont, Senior Product Manager, and Rue Fox, Affordable Housing Industry Principal, affordable housing experts at ResMan, how they would advise operators. Neither was surprised. Rue called the delay “absolutely expected.” Here are the five steps we recommend.
1. Confirm Which Date Applies to Each Program
The new date covers HUD Multifamily programs such as Section 8 Project-Based Rental Assistance (PBRA), Section 202, and Section 811. It does not automatically move other programs. Here is where each program stands as of November 2026.
| Program | Governing Agency | Where HOTMA Stands |
|---|---|---|
| HUD Multifamily | HUD Office of Multifamily Housing | Certifications effective January 1, 2028, or later |
| Low-Income Housing Tax Credit (LIHTC) | State housing finance or allocating agency | Varies by state; many agencies have already acted |
| USDA Rural Development | USDA Rural Housing Service | In effect since July 1, 2025 |
| HOME and Housing Trust Fund | HUD Community Planning and Development | No later than January 1, 2027 |
| Public Housing and vouchers, including Project-Based Vouchers | HUD Public and Indian Housing | January 1, 2027 for most public housing agencies |
Watch for similar names. Project-Based Rental Assistance falls under HUD Multifamily Housing, while Project-Based Vouchers fall under Public and Indian Housing, so the two follow different schedules. Corbin also notes that Rural Development properties have been under HOTMA since July 2025, so teams with those programs should already have made their updates.
Layered properties need the closest look. “The biggest burden still lies with the layered programs,” Rue said. “The constant pressure of waiting and thinking you know, then finding out you do not, is just added stress to an already heavy, stressful workload on the teams.” In some cases, the governing income rules can differ between HUD-assisted LIHTC units and LIHTC-only units on the same property.
Best practice: Keep one property-by-property matrix listing each program, its governing agency, the published date, and the source. Confirm anything unclear with your state agency or program administrator.
2. Stay on Current Procedures for HUD Multifamily
HUD’s announcement directs owners to follow their existing Tenant Selection Plans and Enterprise Income Verification (EIV) policies until they are fully HOTMA compliant. Our experts recommend the same approach.
“I wouldn’t recommend doing anything until all forms have been officially approved and a final 203A has been issued,” Corbin said. Rue’s advice: “Keep doing what you are doing today.”
Hold for now:
- Rewriting Tenant Selection Plans and EIV policies for HUD Multifamily properties.
- Changing income and asset calculations or certification workflows.
- Replacing forms and leases that are not yet final.
3. Preserve the HOTMA Work You Have Already Done
Policy drafts, discretionary decisions, and training materials will still be useful when the requirements are final. Store them in one place and note the assumptions behind each decision, so you can compare them against the final forms and specifications.
Rue would hold steady too. With as many delays as there have been, “until a final notice is out with a true date, I would likely not do anything I have not done already.”
A full retraining effort can wait. Corbin suggests that a refresher may be worthwhile but sees no reason to change course “until further notice.” Schedule formal training once HUD publishes final requirements.
4. Know the Transition Rules
HUD’s announcement sets two rules for the period before January 1, 2028:
- Reviews: HOTMA-related tenant file errors found during Management and Occupancy Reviews will result in observations with corrective actions rather than penalties. Your current program requirements still apply.
- Early compliance: Owners may become fully compliant early by using the rent override function in the Tenant Rental Assistance Certification System (TRACS). Because forms and specifications are not final, we would treat this as an exception and confirm your approach with your Contract Administrator first.
5. Plan Around HUD’s Milestones, Not Just the Deadline
The compliance date has changed four times, so the better indicators of timing are the items HOTMA implementation depends on:
- The final TRACS 203A specification. This is the technical guide software providers build to so HOTMA certifications can be submitted to HUD. HUD posted a draft on September 2, 2026, and it is not yet final. “HOTMA changes are tied to the TRACS 203A spec guide,” Corbin said. “Unless that is approved and provided to vendors to code, then nothing changes at this time.”
- Final form approvals, including the HUD Model Lease and the HUD-50059 certification.
If the specification is released in time, your practical start date will come before January 2028. Corbin points to September 1, 2027, when first reminder notices for January 1, 2028 recertifications go out.
Notice H-2026-07 does not explain why the date moved or lay out a new roadmap, which is one more reason to watch these milestones instead of the calendar. As Rue put it, “I wish there was a magic pill, but there is not.”
What to Ask Your Software Provider
Once HUD finalizes TRACS 203A, your software provider’s readiness will shape your own. Ask these questions now:
- How and when will you communicate your plan after the final 203A is issued?
- Will we be able to test HOTMA certifications before go-live?
- How will the platform handle a portfolio or property with different HOTMA dates by program?
- What training and support will our compliance and on-site teams receive?
- Can we see compliance tasks and deadlines across the portfolio in one view?
Clear answers now will tell you a lot about how the transition will go later.
How ResMan Supports Operators Through HOTMA
When HUD publishes its final specification, building to it is our responsibility, so your team can stay focused on accurate certifications and clean files. Our affordable housing experts are tracking HUD’s forms and TRACS updates, and as Rue told us, “We will keep you up to date as time comes closer.”
ResMan Affordable was designed by industry insiders and brings HUD, LIHTC, and USDA Rural Development compliance together with property management and accounting in one platform. The Compliance Center puts compliance tasks and deadlines on one screen, so your team can spot issues early and nothing slips through the cracks when program rules differ across your portfolio.
If you are evaluating how your current platform will handle HOTMA, or comparing affordable housing compliance software, we can walk through it with you.
Schedule a personalized demo today →
Frequently Asked Questions About the HOTMA Delay
Is HOTMA delayed to 2028?
Yes, for HUD Multifamily Housing programs. HUD Notice H-2026-07, issued November 2, 2026, moved mandatory compliance with HOTMA Sections 102 and 104 to certifications effective January 1, 2028, or later. It is the fourth extension of the original January 1, 2025 date. Other programs, including LIHTC, HOME, and Public Housing, follow their own dates.
Does the January 1, 2028 HOTMA deadline apply to every affordable housing property?
No. The 2028 date applies only to HUD Multifamily Housing programs. USDA Rural Development has required HOTMA since July 1, 2025. HOME, the Housing Trust Fund, and most public housing agencies must comply by January 1, 2027. LIHTC dates are set by each state agency, so layered properties can have more than one deadline.
Which HUD Multifamily programs does the 2028 date cover?
The date covers the programs listed in HUD Notice H 2023-10: Section 8 Project-Based Rental Assistance, Section 202/8, Section 202/162 Project Assistance Contracts, Section 202/811 Project Rental Assistance Contracts, certain non-insured Section 236 projects, Section 811 Project Rental Assistance, and Senior Preservation Rental Assistance Contracts.
What is TRACS 203A, and when will it be final?
TRACS 203A is the release of HUD’s Tenant Rental Assistance Certification System that carries the HOTMA changes. Software providers code to its specification so owners can submit HOTMA certifications. HUD posted a draft specification on September 2, 2026, and has not announced a final release date, which is why most HOTMA changes for HUD Multifamily are on hold.
Can owners comply with HOTMA before January 1, 2028?
Yes. HUD says owners may become fully compliant before January 1, 2028, by using the rent override function in TRACS. Because forms and specifications are not final, treat early compliance as an exception and confirm your approach with your Contract Administrator first. Otherwise, keep following your existing Tenant Selection Plan and EIV policies.
