HOTMA Compliance Updates – as of 4/15/25

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 28^th, 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 will 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 July 1, 2025. Please note that CTCAC has added new fields to 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 led 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. 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 1^st, 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 have 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 but 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 5^th, 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	New Jersey has stated that HOTMA changes should be implemented by January 1^st, 2025. No HOTMA compliant TIC has been released. Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins.
New York (HCR)	Confirmed	HOTMA guidance was released in a memo dated 12/9/24. The agency will implement their HOTMA policies effective 7/1/25. Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins.
New York (HDC)	Confirmed but awaiting agency clarification	HDC has released a new TIC and their 2025 marketing handbook states an effective date of 04/01/2025. We have reached out to the agency for clarification on HOTMA effective date.
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 awaiting agency clarification	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.”  OHFA has not released a HOTMA-compliant TIC and will not accept the NCSHA TIC. OHFA has stated that sites are to use the “current TIC in DevCo and make any manual adjustments necessary to the TIC since it is not yet HOTMA-compliant.” To comply with this request, we have updated the TIC to generate as follows once HOTMA is enabled for the property.
Oklahoma	Confirmed	On December 18, 2024, OHFA announced that the HOTMA implementation date would be January 1, 2025. The agency’s website has been updated with new HOTMA forms. Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins.
Oregon	Confirmed	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.” Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins.
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	As of October 2024, South Dakota Housing Development Authority published HOTMA guidance, and a HOTMA compliant TIC was posted in November 2024.  SDHDA has not confirmed implementation date and we’ve reached out for clarification. Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins.
Tennessee	Confirmed	THDA announced that all HOTMA changes as described should be implemented or begin on January 1, 2025. Pre-planned actions with an effective date of January 1, 2025, through April 30, 2025, such as annual recertifications, will be subject to phased-in considerations. Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins.
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 12^th, 2024: “UHC will not enforce HOTMA-related file errors (i.e., will not issue 8823’s) discovered prior to January 1, 2025.”
Vermont	Confirmed	Vermont has released a HOTMA compliant TIC using the NCSHA template and announced a HOTMA compliance date of 07/01/2025. Please note that this TIC includes tax refund considerations which will require an update to Voyager Affordable plug-ins.
Virginia	Confirmed	Virginia Housing has released a new TIC effective January 1, 2024. As of 10/18/2024 the agency has delayed mandatory compliance with 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	On January 9^th, 2025 WSHFC released a new HOTMA compliance TIC. Washington has stated that HOTMA changes should be implemented by January 1st, 2025.
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.”
Wyoming	Confirmed	WDCA has posted a HOTMA compliant TIC and confirmed that they are targeting a 01/01/2026 for an implementation date. A new HOTMA manual will be released later this year.

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	In January 2025, updated versions of VAWA 5380 and 5382 were posted. Due to some uncertainty and the removal of supporting documents on HUDclips, Yardi is awaiting further guidance from HUD to update our standard forms accordingly. As of November 2024, we are awaiting HUD forms for review. 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 31^th, 2024, HUD 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, 2026. 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: