These are the five HOTMA facts I would make sure every property manager, compliance specialist and regional manager understands in 2026:
1. The Multifamily HOTMA compliance deadline is now January 1, 2027
This is probably the most important date managers need to know right now. HUD issued Notice H 2025-07 on December 17, 2025, extending the mandatory Multifamily Housing compliance date for HOTMA Sections 102 and 104 from January 1, 2026 to January 1, 2027.
That means managers should be using 2026 to prepare their policies, software, certification procedures, staff training and file-review processes rather than assuming HOTMA disappeared.
Manager takeaway: Put January 1, 2027 on your compliance calendar now.
2. HOTMA fundamentally changes how assets are treated
HOTMA Section 104 created an asset limitation for certain HUD programs. The statutory starting point was $100,000 in net family assets, adjusted annually for inflation, and ownership of real property suitable for occupancy can also affect eligibility.
This makes asset questions considerably more important during the certification process.
Managers need to understand the differences between:
assets → excluded assets → asset income → imputed income → real property → net family assets → program eligibility.
And don't memorize the original $100,000 figure forever—HUD provides for annual inflation adjustments.
3. HOTMA changes deductions—and some numbers will change every year
Under the HOTMA final rule, the elderly/disabled family deduction increased from $400 to $525 at the rule's baseline, and the dependent deduction is also subject to annual inflation adjustments.
Another major change involves unreimbursed health/medical and attendant-care expenses: the qualifying threshold increases from 3% to 10% of annual income, with phase-in and hardship provisions for affected families.
Manager takeaway: Stop building permanent cheat sheets around a single year's HOTMA numbers. Several thresholds and deductions are inflation-adjusted annually, so your compliance materials need a yearly update process.
4. Interim recertification rules changed—and HUD issued new guidance in 2026
HOTMA significantly changed income-review and interim-reexamination requirements. This isn't an area where managers should rely on “the way we've always done interims.”
HUD issued Housing Notice 2026-05 specifically amending HOTMA implementation guidance related to interim reexaminations. PIH issued corresponding Notice PIH 2026-09.
That matters because managers need to know when an interim is required, what income changes must be processed, and which program's rules apply.
Manager takeaway: If your company's interim-recertification SOP was written before HOTMA—or even based solely on older HOTMA training—review it again against the 2026 guidance.
5. HOTMA isn't simply “a new version of the 4350.3”
HOTMA was signed into law on July 29, 2016, and HUD's final rule implementing Sections 102, 103 and 104 was published in 2023. It makes significant changes involving annual income, assets, deductions, income reviews and program eligibility.
This is especially important because HUD has explicitly warned that HOTMA implementation supersedes portions of older subregulatory guidance, including portions of HUD Handbook 4350.3 REV-1, CHG-4.
So a manager saying “I checked the 4350.3” may no longer be enough.
The correct question becomes:
“What is the current controlling HUD requirement for this issue?”
That could mean the regulation, HOTMA final rule, implementation notice, subsequent HUD notice, FAQ, updated form, program-specific guidance, or the portions of 4350.3 that remain applicable.
The numbers managers should remember
2016 — HOTMA became law.
2023 — HUD published the final rule implementing Sections 102, 103 and 104.
January 1, 2027 — current mandatory HOTMA compliance date for covered HUD Multifamily Housing owners under Notice H 2025-07.
