HUD has officially announced a long-anticipated delay in the implementation of key provisions of the Housing Opportunity Through Modernization Act (HOTMA). Through the release of Notice H 2025–07, the Department of Housing and Urban Development has extended the compliance deadline for HOTMA Sections 102 and 104 for Multifamily Housing programs. This update provides much-needed clarity for owners and agents preparing for significant changes to income and asset determinations.
What Notice H 2025–07 Means for Multifamily Housing
New Compliance Date: January 1, 2027
Under the new guidance, owners must be in full compliance with the HOTMA final rule for certifications effective on or after January 1, 2027. This replaces the prior compliance deadline of January 1, 2026 and applies to updated income and asset documentation requirements that have been central to HOTMA implementation planning.
Prior Guidance Superseded
Notice H 2025–07 formally supersedes Notices H 2025–03 and H 2024–09. The extension applies to all Multifamily Housing programs covered under Notice H 2023–10, ensuring consistency across HUD programs affected by HOTMA.
What Owners and Agents Should Do Next
For Multifamily owners and administrators, this extension provides additional time to update internal policies, train staff, and coordinate with software providers and compliance partners. While the delay reduces immediate pressure, HUD has made it clear that full compliance will be expected in 2027. Stakeholders should use this extended timeline strategically to ensure a smooth and compliant transition when HOTMA requirements take effect.