Revised Compliance Date: Implementation of Sections 102 and 104 of the Housing Opportunity Through Modernization Act of 2016 (HOTMA)

Notice H 2025–07

Issued: 12/17/2025

Expires: This Notice remains in effect until amended, superseded, or rescinded Supersedes: Notices H 2024–09, H 2025–03

Cross-references: Notice H 2023–10

SPECIAL ATTENTION OF

Multifamily Asset Management Division Directors

Multifamily Contract Administrators

Multifamily Project Owners

Multifamily Regional Center Directors

Revised Compliance Date: Implementation of Sections 102 and 104 of the Housing Opportunity Through Modernization Act of 2016 (HOTMA)

1. PURPOSE

Section 6.2 of “Implementation Guidance: Sections 102 and 104 of the Housing Opportunity Through Modernization Act of 2016 (HOTMA)” (Notice H 2023–10) establishes a date of January 1, 2025, by which Multifamily Housing (MFH) Owners must be in full compliance with the HOTMA final rule1 The purpose of this Notice 2025–07 is to extend the compliance date to January 1, 2027.

2. BACKGROUND

Section 6.2 of Notice H 2023–10 requires Multifamily Housing Owners to be in full compliance with the HOTMA final rule and HUD’s updated income and asset documentation requirements for income certifications having an effective date on or after January 1, 2025. HUD later published Notice H 2025–03 further extending the compliance date to January 1, 2026. This Notice however extends the compliance date to January 1, 2027. The requirement applies to Owners participating in the programs listed in section 4 (Applicability) of Notice H 2023–10.

3. REVISION OF DATE

The compliance dates stated in section 6.2 of Notice H 2023–10 is hereby revised from January 1, 2025, to January 1, 2027.

4. FURTHER INFORMATION

For questions regarding this Notice, please contact MFH_HOTMA@hud.gov.

Frank Cassidy Principal Assistant Secretary for Housing

1 Housing Opportunity Through Modernization Act of 2016: Implementation of Sections 102, 103, and 104, 88 Fed. Reg. 9600 (Feb. 14, 2023).

Read Notice H 2025–07.

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