On September 29, HUD published Notice PIH 2023-17, which contains implementation guidance for Sections 102 and 104 of the Housing Opportunity Through Modernization Act of 2016 (HOTMA). HOTMA Sections 102 and 104 contain significant changes to the requirements for tenant income and assets, respectively, for public housing and Section 8 program participants. The effective date of the final HOTMA rule for covered public housing agencies (PHAs) and owners of HUD-assisted multifamily housing is Jan. 1, 2024; however, the compliance date for the rule is Jan. 1, 2025. Each PHA will set its own compliance date no later than Jan. 1, 2025, dependent on when its annual plan is due to HUD. Multifamily owners are required to update tenant selection plans and income verification systems to comply with the final rule by March 31, 2024, but will not be penalized for HOTMA-related errors during Management and Occupancy Reviews until Jan. 1, 2025.
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