At long last, HUD has officially announced that Multifamily owners can implement HOTMA regulations in stages during calendar year 2024. What does this mean? It is not necessarily a simple, short answer.
The Final Rule’s effective date remains January 1, 2024. However, HUD has acknowledged how significant of a program shift this will be for all stakeholders. Implementation will be an ongoing process that occurs during 2024, culminating in a final new implementation deadline of December 31, 2024.
When your property takes certain steps during the year will be dependent on what TRACS compliance software vendor you use and when you install your TRACS Version 2.0.3.A update. Make sure you are in contact with your software vendor who can provide you with more specifics regarding their timeline.
In the meantime, don’t panic. Here are some things you can consider when creating your own game plan for implementation and some crucial dates to consider:
Disclaimer: HUD outlines several administrative requirements for owners throughout the Rule and the Notice that followed. This list is not designed to be an all-inclusive chart of tasks, but rather, key benchmarks to consider when laying out your next steps.
- The first benchmark date is March 31, 2024. By March 31, 2024, Multifamily housing owners must update their Tenant Selection Plans, EIV Policies and Procedures, House Rules, and other leasing and occupancy policies to reflect HOTMA rules and discretionary policies. We are currently updating our policies available for purchase to reflect HOTMA changes so that clients can ensure they have the updated versions well in advance of this March 2024 deadline. If you are interested in purchasing policies from us, don’t delay. We will be satisfying those orders first-in-first-out and orders are already coming in. When you begin using these policies is a more complex discussion covered in our live trainings!
- Once your TRACS 2.0.3.A software update is installed, more comprehensive implementation begins. However, because all software vendors will have unique implementation schedules for their users, customers will have varied start dates for this stage. Regardless of when it starts for you, all owners will be tasked with:
- Implementing those policies updated by March 31, 2024;
- Notifying residents of upcoming lease changes that will occur at the end of their lease term;
- Implementing new policies for hardships and phase-in of new deductions thresholds;
- Incorporating in new calculation methodologies at annual and interim re-examinations;
- Re-evaluating eligibility and continued eligibility of all Section 8 households based on new Asset Disqualifiers (Including Section 8/202s);
- Incorporating new rental calculation methodologies for all households.
If you want more information on the HOTMA Final Rule, reach out to the DeSilva Housing Group today. We are a training and consulting firm that specializes in HUD compliance for property owners and managers in the affordable housing industry. We offer valuable resources to keep your property compliant.