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HOTMA Compliance News

Updated as of March 12, 2024

We're committed to keeping you informed about the latest developments regarding TRACS 2.0.3.A and the Housing Opportunity Through Modernization Act (HOTMA).

As you may have already heard or read, in February 2023, the U.S. Department of Housing and Urban Development (HUD) began the final steps to update the Tenant Rental Assistance Certification System (TRACS). As of today鈥檚 date, final requirements, final MAT Guide and approved forms are still pending from HUD for TRACS 2.0.3.A. This update is essential for implementing key sections of HOTMA, specifically Sections 102, 103 and 104, passed in 2016.

On Feb. 2, 2024, HUD released an important notice, , for HOTMA outlining the implementation details for HOTMA, replacing a previous notice from Sept. 29, 2023.

This new guidance highlights that the initial deadline of Jan. 1, 2024, for implementing HOTMA's regulations was not met due to delays in updating the TRACS software. As a result, the implementation process is expected to continue into 2025.

On Feb. 28, 2024, the Office of Multifamily Housing Programs published a extending the HOTMA compliance date in Section 6.2 of for owners to update their Tenant Selection Plan (TSP) and Enterprise Income Verification (EIV) Policies and Procedures (P&P) from March 31, 2024, to May 31, 2024. although they should continue following their current TSPs and EIV system policies and procedures until the software aligns with TRACS 2.0.3.A.

Many state agencies have begun adopting HOTMA rules for their TICs. The following is a status of State Housing Agencies that have issued HOTMA supported Tenant Income Certification forms. Please note that some States have released new TICs to update the Passbook rate but are not yet supporting full HOTMA rules. These are indicated with an *.

State

Description

Posted to State Agency Website

Arizona

Arizona Tenant Income Certification

Arkansas

Arkansas Tenant Income Certification *

Connecticut

Connecticut Tenant Income Certification

Delaware

Spectrum Federal Income Certification

Kansas

Kansas Tenant Income Certification

Kentucky

Kentucky Tenant Income Certification

Massachusetts

Spectrum Federal Income Certification

Michigan

Michigan Tenant Income Certification

Michigan

Michigan Self-Certification

Mississippi

Mississippi Tenant Income Certification*

Missouri

MHDC - Exhibit B

Spectrum

Spectrum Federal Income Certification

Texas

Texas Income Certification

Virginia

Virginia Tenant Income Certification

West Virginia

Spectrum Federal Income Certification

Please note this information is continuously evolving. Please check back for updates.

For additional information on HOTMA please visit:

Questions on compliance for Multifamily can be sent to MFH_HOTMA@hud.gov.