Timeline for MFH Owners' Compliance with HOTMA Rules and HUD Requirements By March 31, 2024
On or After January 1, 2025
Update Tenant Selection Plans and EIV Policies: MFH Owners must revise their Tenant Selection Plans and EIV policies to align with HOTMA rules and discretionary policies. The revised Tenant Selection Plan must be made publicly available. Note: MFH Owners should continue to follow their existing plans and policies until their software is compliant with TRACS 203A. Once Software is HOTMA Compliant: Implementing Revised Policies and Procedures: Provide tenants with 60 days' notice of lease modification post the 60 days' notice period. Start using revised Model Leases at the end of a family’s lease term. Implement revised Tenant Selection Plans and EIV policies and procedures. Comply with HOTMA regulations for all tenant data submissions. Inform families about the new income determination process per HOTMA. Use the revised Tenant Consent form (form HUD–9887/9887A) and Fact Sheets.
Monitoring Compliance BEFORE January 1, 2025 HUD's Oversight: No penalties for HOTMA-related tenant file errors during Management and Occupancy Reviews (MORs). Contract Administrators will issue observations with corrective actions for errors.
HUD's Enhanced Monitoring: Contractor Administrators will issue HOTMA-related findings during MORs. Compliance with all aspects of HOTMA is expected. MFH Owners must correct all HOTMA-related observations that were issued by Contract Administrators during 2024.
Additional Notes MFH Model Leases Update: New HUD-approved leases must be used once HOTMA is fully implemented. Specific procedures outlined for renewing families under the revised Model Lease.
Important Notes Lease Modification Process: Notice delivery methods and timelines. Tenant's response options and implications. Compliance with HUD's rules for notice delivery. HOTMA Implementation: Reporting requirements for families under old leases. Conditions for interim reexaminations. Prohibition of modifications to Model Leases without HUD approval.
Get more detailed information in Section 6.2 of the Implementation Guidance: https://www.hud.gov/sites/dfiles/OCHCO/documents/2023-10hsgn.pdf
By January 1, 2025: Mandatory Full Compliance: Full adherence to HOTMA final rule is required. Correct all HOTMA-related observations issued in 2024. Failure to implement HOTMA may result in being found in default of business agreements with HUD.
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