HOTMA Compliance News

We're committed to keeping you informed about the latest developments regarding TRACS 2.0.3.A and the Housing Opportunity Through Modernization Act (HOTMA).

As you may have already heard or read, in February 2023, the U.S. Department of Housing and Urban Development (HUD) began the final steps to update the Tenant Rental Assistance Certification System (TRACS). As of today’s date, final requirements, final MAT Guide and approved forms are still pending from HUD for TRACS 2.0.3.A. This update is essential for implementing key sections of HOTMA, specifically Sections 102, 103 and 104, passed in 2016.

On Feb. 2, 2024, HUD released an important notice, Notice H 2023-10, for HOTMA outlining the implementation details for HOTMA, replacing a previous notice from Sept. 29, 2023.

This new guidance highlights that the initial deadline of Jan. 1, 2024, for implementing HOTMA's regulations was not met due to delays in updating the TRACS software. As a result, the implementation process is expected to continue into 2025.

On Feb. 28, 2024, the Office of Multifamily Housing Programs published a Housing Notice extending the HOTMA compliance date in Section 6.2 of Notice H 2023-10 for owners to update their Tenant Selection Plan (TSP) and Enterprise Income Verification (EIV) Policies and Procedures (P&P) from March 31, 2024 to May 31, 2024, although they should continue following their current TSPs and EIV system policies and procedures until the software aligns with TRACS 2.0.3.A.

Many state agencies have begun adopting HOTMA rules for their TICs. The following is a status of State Housing Agencies that have issued HOTMA supported Tenant Income Certification forms. Please note that some States have released new TICs to update the Passbook rate but are not yet supporting full HOTMA rules. These are indicated with an *.