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We have received information from many Housing Finance Agencies (HFAs) about their plans to implement the Housing Opportunity Through Modernization Act (HOTMA) for the Low-Income Housing Tax Credit (LIHTC) program. Below, you will find the status of states that have either confirmed in writing or discussed adoption of HOTMA. We will continue to update this information as we learn more. It is important to note that this information is subject to change, even for states that are currently marked as ‘Confirmed’.
Please note, some states have released new Tenant Income Certifications to update the passbook rate, however, if additional HOTMA guidance or instruction has not been released those HFAs will not appear on the list below.
| State/Territory | HOTMA Adoption Status | Additional Notes |
| NCSHA | Confirmed | As of August 28th, 2024, NCSHA has released model forms. Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins. |
| Alabama | Confirmed | In 09/2024, Alabama confirmed they’ll be moving forward with the NCSHA TIC. |
| Alaska | Confirmed | On April 12, 2024, AHFC stated that “all Programs are required to implement these changes no later than September 1, 2024. While implementation is required, no noncompliance will be identified until January 1, 2025, to allow Owners, Partners, and Manager’s time to complete training, update internal policies and procedures, and complete implementation.” |
| Arizona | Confirmed | On September 24, 2024, Arizona extended the HOTMA compliance date to 07/01/2025 following HUD Guidance. |
| Arkansas | Confirmed but documentation not released | ADFA has released a TIC that is partially updated with passbook rate. We have confirmed with ADFA that they are working on guidance and HOTMA need not be implemented until 01/01/2025. |
| California | Confirmed | CTCAC has announced that implementation will not be mandatory effective July 1, 2025. CTCAC’s monitoring guidance for HOTMA policies is available to projects that opt to implement the new policies beginning January 1, 2024. Implementation can be partial or full implementation. Income and asset documentation shall be collected within 120 days of the July 1, 2025. Please note that CTCAC has added new fields on the TIC related to assets which will require an update to Voyager Affordable plug-ins. |
| Connecticut | Confirmed | On 09/24/2024 Spectrum updated their website to use the NCSHA TIC. Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins. |
| Colorado | Confirmed | On 06/24/2024 CHFA released an updated manual and HOTMA compliant Tenant Income Certification. On 09/26/2024 CHFA decided to similarly extend the mandatory implementation date of HOTMA to July 1, 2025, for the Housing Tax Credit and CHFA multifamily loan programs. However, CHFA is allowing flexibility for properties that choose to implement prior to July 2025. |
| Delaware | Confirmed | On 01/04/2024 Spectrum Compliance website for DE was updated with a HOTMA updated Tenant Income Certification. |
| Georgia | Confirmed | DCA has announced a HOTMA effective date of 01/01/2024, with a compliance date for implementation will be no later than January 1st of 2025. This delay allows property managers and management companies additional time to update systems (i.e., software, staff, forms, etc.) for the upcoming implementation. Property managers/management companies will not be penalized for HOTMA-related errors until the compliance deadline (January 1st, 2025). |
| Hawaii | Confirmed | On December 12, 2023, HHFDC held an affordable program training lead by Spectrum Compliance which included HOTMA regulation showing an effective date of 01/01/2024. In 09/2024 Spectrum posted a new HOTMA compliant TIC which has now been programmed. |
| Idaho | Confirmed | IHFA has posted a new HOTMA-compliant TIC (similar to NCSHA’s version). Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins. |
| Illinois | Confirmed | On 09/10/2024 IHDA released new forms for HOTMA including a TIC, with an implementation effective 01/01/2025. |
| Indiana | Confirmed | IHDCA has updated forms for HOTMA on April 1, 2024, including a HOTMA TIC. IHCDA will make findings for HOTMA related noncompliance in 2024 and will require necessary corrective action. However, IHCDA will not impose penalties for HOTMA specific issues during calendar year 2024 or impose fines for items specifically linked to HOTMA changes. |
| Iowa | Confirmed | IFA has posted a new HOTMA-compliant TIC (almost identical to NCSHA’s version), Compliance Manual for LIHTC, HOME, and NHTF, and HOTMA-compliant forms. Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins. |
| Kansas | Confirmed | On November 10, 2023, Kansas Housing released an updated TIC and compliance manual draft, confirming they will adopt HOTMA on January 1, 2024. |
| Kentucky | Confirmed | In December 2023 KHC issued HOTMA Guidance and an updated TIC. The guidance state “Changes should be implemented for all households moving in or recertifying after January 1, 2024.” |
| Louisiana | Confirmed | Louisiana has provided a HOTMA TIC (similar to NCSHA’s version) and will implement HOTMA effective for January 1, 2025 move-ins and annual recertifications with an effective date of April 1, 2025. Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins. |
| Maine | Confirmed but documentation not released | Maine confirmed in Asset Management Notice #2024-01 that guidance will be coming soon. An effective date of 01/01/2024 has been set, but January 1st, 2025, is the compliance deadline. No HOTMA TIC has been released. |
| Maryland | Confirmed but documentation not released | Maryland LIHTC properties may elect to follow pre-HOTMA standards during 2024. Properties may adopt HOTMA within sixty (60) days of the property’s software being ready for implementation. No TIC has been officially released. |
| Massachusetts | Confirmed | In 09/2024 Spectrum updated their website with a new HOTMA compliant TIC. |
| Michigan | Confirmed | MSHDA released a new memo and HOTMA TIC on January 3, 2024 with guidance that states “MSHDA is looking to have all HOTMA changes implemented by 1/8/2024 for any certifications completed on or after that date.” |
| Minnesota | Confirmed but documentation not released | Affordable Housing Connections has delivered a new TIC but has now confirmed they are now awaiting more guidance from HUD. Minnesota Housing Finance Agency (MHFA) has not released guidance on the implementation of HOTMA. |
| Mississippi | Confirmed | MHC has posted a new HOTMA compliant TIC as of 09/2024, and we have reached out with questions. |
| Missouri | Confirmed | On November 20, 2023, Missouri Housing Development Commission published an updated TIC and HOTMA Manual to adopt HOTMA as of January 1, 2024. |
| Montana | Confirmed | Montana Housing provided an updated copy of their TIC on 10/08/2024. |
| Nevada | Confirmed by documentation not released | Nevada Housing Division has stated that “HOTMA’s program updates are effective January 1, 2024, and are mandated to be fully compliant January 1, 2025. During this transitioning period properties should try to be “as compliant as possible”. NHD will notate errors during audits completed in 2024 and corrective action should be taken. The HOTMA errors notated in 2024 will not be reported.” Nevada has not released a new TIC with HOTMA changes. |
| New Hampshire | Confirmed but documentation not released | On December 5th, 2023, Section 8 and Section 811 properties must follow HUD MFH guidance on HOTMA implementation; however, at this time, New Hampshire Housing is recommending that all other properties hold off on HOTMA implementation until guidance is received. |
| New Jersey | Confirmed but documentation not released | New Jersey has stated that HOTMA changes should be implemented by January 1st, 2025. No HOTMA compliant TIC has been released. |
| North Carolina | Confirmed | The North Carolina Housing Finance Agency has recently posted a fact sheet on their website announcing for HOTMA is in effect for January 1, 2024, move-ins and annual recertifications with an effective date of April 1, 2024. An updated TIC was posted on NCHFA’s website on 07/24/2024. |
| North Dakota | Confirmed | NDHFA will note HOTMA related non-compliance issues identified in calendar year 2024 and will require necessary corrective action. However, NDHFA will not impose penalties or HOTMA specific issues during calendar year 2024- i.e. will not issue 8823s for items specifically linked to HOTMA changes. As of 10/2024, North Dakota has adopted the NCSHA TIC. Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins. |
| Ohio | Confirmed but documentation not released | On September 26, 2024, Ohio revised their timeline in response to HUD’s announcement stating “OHFA will implement HOTMA on January 1, 2025, however, mandatory use of HOTMA rules will only be applicable for initial tenant certifications and recertifications effective May 1, 2025, onward.” Ohio has not yet released a HOTMA compliant TIC. Ohio has not yet released a HOTMA compliant TIC. |
| Oklahoma | Confirmed by documentation not released | On December 13, 2023, Oklahoma Housing Finance Agency provided a newsletter stating “Over the next year, OHFA will be updating our program guidelines, including policies, procedures, and internal systems, and conduct software updates to implement HOPWA across our Housing Development Programs. Once updated, OHFA will sponsor a training for all owners/managers on the new implementation and guidance for HOTMA.” This included a note that all must comply with HOTMA final rule no later than 01/01/2025. |
| Oregon | Confirmed but documentation not released | Oregon plans to fully implement HOTMA and begin monitoring under HOTMA guidelines effective January 1, 2025; however, from January 1, 2025 through June 30, 2025, findings specific to new HOTMA requirements will be documented as “observations.” Oregon has not yet released a HOTMA compliant TIC. |
| Pennsylvania | Confirmed but documentation not released | Pennsylvania Housing Finance Agency (PHFA) announced during their training that they are adopting (HOTMA) and are developing a new Tenant Income Certification (TIC) form. PHFA’s HOTMA implementation date will be 7/1/2025. PHFA has published some resources on their website but has not released a new TIC. |
| Rhode Island | Confirmed | On 10/04/2024 Rhode Island confirmed they will be adopting the NCSHA TIC. Rhode Island has stated that implementation will not likely be earlier than 7/1/25. Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins. |
| South Carolina | Confirmed | South Carolina Finance and Development Authority confirmed in July 2024 that HOTMA will be implemented effective October 1, 2024; however, the HOTMA policy will not be enforced until January 1, 2025. On 08/28/2024 confirmed they will be adopting the NCSHA TIC. Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins. |
| South Dakota | Confirmed but documentation not released | South Dakota has released HOTMA guidance. No HOTMA compliant TIC has been released. |
| Texas | Confirmed | Texas Department of Housing and Community Affairs stated during a training session that they will begin conducting audits for HOTMA starting on January 1, 2024. |
| Utah | Confirmed | UHC has released a new TIC and Under $50k form. UHC Guidance from memo on March 12th, 2024: “UHC will not enforce HOTMA-related file errors (i.e., will not issue 8823’s) discovered prior to January 1, 2025.” |
| Virginia | Confirmed | Virginia Housing has released a new TIC effective January 1, 2024. As of 10/18/2024 the agency has delayed mandatory compliance of HOTMA. HOTMA compliance will be required for all tenant income certifications by July 1, 2025, or the date required for all programs by HUD or the IRS. |
| Washington | Confirmed but documentation not released | Washington has stated that HOTMA changes should be implemented by January 1st, 2025. No HOTMA compliant TIC has been released. |
| West Virginia | Confirmed | On 01/04/2024 Spectrum Compliance website for WV was updated with a HOTMA updated Tenant Income Certification. |
| Wisconsin | Confirmed | HOTMA compliant TIC was released 04/05/2024 and this document is now available. Guidance from WHEDA: “The effective date for HOTMA implementation in Housing Tax Credit (HTC), aka Low-Income Housing Tax Credit (LIHTC), and WHEDA Financed Properties is 01/01/2024. However, some changes may be delayed due to pending updates by major software vendors.” |
In addition to tracking Housing Finance Agencies, we are closely monitoring HUD’s HOTMA resource page and newsletters, along with RHS resources and training, for updates related to all HUD multifamily programs and Rural Development.
| Agency | HOTMA Adoption Status | Additional Notes |
| HUD | Confirmed but documentation not released | On 09/20/2024 HUD provided Notice H 2024-09 which extended the compliance date of HOTMA to July 1, 2025. HUD has updated the requirement for Tenant Selection Plan and EIV policies and procedures to be completed May 31, 2024. |
| HOME HTF HOPWA CDBG ESG CoC CPD | Confirmed but documentation not released | On December 8th, 2023, HUD announced in Federal Register/Vol. 88, No. 235 that they are extending the compliance date for the HOME Investment Partnerships Program (‘‘HOME’’), HOME-American Rescue Plan program, Housing Trust Fund (‘‘HTF’’), Housing Opportunities for Persons With AIDS (‘‘HOPWA’’), Community Development Block Grant Program (‘‘CDBG’’), Emergency Solution Grants (ESG), Continuum of Care (CoC) programs, and CPD programs funded through competitive process (‘‘CPD programs’’) until January 1, 2025. Please note: In certain situations, housing finance agencies oversee the HOME program. Therefore, timelines and expectations should be confirmed with them separately. |
| RHS | Confirmed but documentation not released | Like HUD, we are awaiting updated forms and guidance for the Rural Development program. There is a new 3560-8 that is expected to be released in October of 2024. RHS also posted a memorandum in February 2024 that provided the program specific administrator exceptions from HOTMA. Update 10/03/2024: To align with HUD, RHS Multifamily Housing is extending full implementation of applicable HOTMA regulations until July 1, 2025. All MFH tenant certifications effective on or after July 1, 2025, must comply with HOTMA requirements. |
Based on the considerable number of local programs and the limited guidance available, we are unable to track their status regarding HOTMA.
Voyager clients: For more details, please log into Client Central and review the recorded webinars available under Product Resources -> Video Library -> Filter on Affordable.
Breeze clients: For more details, please log into Breeze and review Help Center -> Instructional Webinars.
RightSource clients: For more details, please log into RightSource Help and review the new HOTMA section.
For additional information regarding HOTMA please visit:
- HUD’s Multifamily HOTMA Resources
- National Center for Housing Management
- NCSHA