With the January 1, 2026, deadline for full Housing Opportunity Through Modernization Act (HOTMA) implementation approaching, the multifamily sector within the U.S. Department of Housing and Urban Development (HUD) faces significant uncertainty. Despite repeated requests from Property Owners, Contract Administrators, and HUD Field Office Staff, essential regulatory resources and guidance remain unavailable. The industry faces a state of chaos – a predicament that HUD can prevent. Who in HUD’s leadership will respond to the industry’s urgent calls for guidance?
The absence of final Tenant Rental Assistance Certification System (TRACS) specifications and OMB-approved HUD forms makes full compliance and software updates impossible. The industry must now contemplate regressing back to outdated rent calculation methods and manual overrides that negate automated error checking functionality that’s been in place for over 20 years. The inevitable outcome of these measures is increased likelihood of improper subsidy payments and practices that undermine decades of progress in improving the financial integrity to subsidy disbursements funded by taxpayer dollars.
Industry stakeholders are experiencing heightened stress and uncertainty, with both program participants and oversight staff left in limbo. Immediate action from HUD leadership is necessary to provide the guidance required for effective implementation. Neglecting to address it is not only disrespectful to program participants, but also adversely affects HUD’s reputation as a responsible federal agency.
By signing our petition, you are advocating for increased accountability and immediate communication from HUD. This is not only a step towards ensuring regulatory compliance, but also towards fostering a predictable and stable TRACS 203A implementation environment for all entities within the Multifamily sector.
Please consider participating in our effort to encourage HUD’s immediate communication with the industry. Sign here.

