HUD’s HOTMA Delay to 2028: What PHAs Need to Know Before January 1, 2027 

At PHADA’s 2026 Legislative Forum in September 2026, staff from HUD’s Office of Housing announced that the HOTMA compliance date for Multifamily Housing programs, including Project-Based Rental Assistance (PBRA), will move from January 1, 2027 to January 1, 2028. HUD staff said a formal notice is moving through approval channels and is expected in the coming weeks. 

That announcement is going to travel fast, and it is going to be shortened to “HOTMA got pushed to 2028.” For most PHAs, that shorthand is wrong. The delay applies to Multifamily Housing programs run by HUD’s Office of Housing. It does not apply to programs run by the Office of Public and Indian Housing (PIH). For public housing, Housing Choice Vouchers, and Project-Based Vouchers, the compliance date set in Notice PIH 2026-15 is still January 1, 2027. 

This post separates the two dates, explains why they differ, and lays out what a PHA needs to have in place over the next 100 days. 

What Was Announced 

The announcement came from HUD Office of Housing staff, speaking at the Forum, and was reported by PHADA. Three points were made: 

• The Multifamily Housing compliance date for HOTMA Sections 102 and 104 will move to January 1, 2028. 
• PBRA is included in the delay. 
• A formal HUD notice is in the approval pipeline and is expected to publish in the coming weeks. 

As of this writing, HUD has not published that notice. Until it does, the controlling Multifamily guidance remains Notice H 2025-07, issued December 17, 2025, which set the January 1, 2027 date. The 2028 date should be treated as announced but not yet official. 

This would be the fourth compliance date for Multifamily HOTMA. The original date was January 1, 2025. It moved to January 1, 2026 under Notice H 2025-03, then to January 1, 2027 under Notice H 2025-07. Each extension was tied to HUD systems work, primarily the TRACS 203A release, the revised model leases, and updates to Handbook 4350.3. 

What Has Not Changed 

On May 14, 2026, HUD published Notice PIH 2026-15. It states that starting January 1, 2027, HUD will enforce compliance with all provisions of HOTMA Sections 102 and 104 for PHAs administering HCV, PBV, Moderate Rehabilitation, Moderate Rehabilitation SRO, and Public Housing. Every Form HUD-50058 transaction with an effective date on or after January 1, 2027 must be HOTMA-compliant. PHADA has confirmed that the Office of Housing announcement does not touch this date. 

The practical consequence is spelled out in the notice itself. PHAs that begin annual reexaminations 120 days before the effective date needed to start collecting and verifying income under HOTMA policies in September 2026. For agencies on that cycle, HOTMA compliance is not a January project. It started this month. 

Two groups of PHAs are excluded from the January 1, 2027 date, with their deadlines still to be announced by HUD: 

• Moving to Work agencies, both initial and expansion. HUD is still building the IMS/PIC changes needed to accept HOTMA-compliant MTW submissions. 
• PHAs that use only HUD’s Family Reporting Software. HUD plans to replace FRS with a web-based application that produces the 2024 HUD-50058. 

Everything already in force stays in force. The provisions Notice PIH 2024-38 required by July 1, 2025, including the updated income exclusions, revised definitions, and de minimis error rules, are not affected by either the PIH date or the Multifamily delay. 

Why the Two Dates Are Different 

HOTMA is one law, but HUD implements it through two offices with two sets of systems. 

• The Office of Housing runs Multifamily programs such as PBRA, Section 202, and Section 811. Owners report through TRACS on Form HUD-50059. Full HOTMA compliance there depends on the TRACS 203A release, which is still in development. 
• PIH runs public housing and the voucher programs. PHAs report through IMS/PIC on Form HUD-50058. PIH has built a workaround that lets agencies report HOTMA-compliant data now, without waiting for a new system. 

Because PIH solved its systems problem and the Office of Housing has not, the two offices are on different clocks. That is the whole explanation. It is not a policy disagreement, and it does not signal that PIH will follow. 

What Full Compliance Means on January 1, 2027 

For PIH programs, Notice PIH 2026-15 provides two ways to report HOTMA-compliant data: 

• The 2024 Form HUD-50058. HUD is updating IMS/PIC to accept the 2024 version of the form, which was built for HOTMA. PHAs whose software can produce it may begin submitting as soon as the system and vendor are ready. 
• The 2020 Form HUD-50058 with alternative instructions. PHAs that cannot convert in time must submit HOTMA-compliant data on the current form using Appendix B of the notice. The PHA enters “HOTMA” in field 2s to flag the submission. HUD has converted seven fatal errors on asset and allowance fields to warnings so the form is not rejected. The alternative instructions are temporary. 

On the policy side, the provisions that take effect for PIH programs on January 1, 2027 include the items that were held back in 2025 because IMS/PIC could not accept them: 

• Net family assets are calculated under the HOTMA definition. Imputed asset income applies only when net assets exceed the annually adjusted threshold, which is $54,898 for 2027, and only for assets where actual income cannot be determined. The 2027 passbook rate is 0.38 percent. 
• Self-certification of net family assets under the threshold is permitted, with third-party verification required at least every three years. 
• The medical and disability expense deduction threshold moves from 3 percent to 10 percent of annual income, with hardship relief that phases families in at 5 percent and 7.5 percent. 
• The dependent and elderly or disabled family allowances are adjusted annually for inflation. For 2026, the dependent deduction is $500, not the $480 default still printed on the form. 
• Interim reexamination rules change, including when a PHA must and must not conduct a full interim, and how mid-cycle updates are filed. 
• Permissive deductions may be offered in HCV, PBV, and Mod Rehab, not only in public housing, if the PHA adopts them in policy. 

Each of these requires an Administrative Plan or ACOP change, staff training, and a software setting. None of them can be turned on the week of January 1. 

If Your Agency Has Both PIH and Multifamily Units 

Many PHAs administer PBV units under PIH rules and also own or manage PBRA units, including RAD conversions to PBRA, under Multifamily rules. If the 2028 date is confirmed, those agencies will run two HOTMA timelines for the same family types, sometimes in the same building. 

• PBV units, including RAD PBV conversions, follow PIH. Compliance date: January 1, 2027. 
• PBRA units, including RAD PBRA conversions, follow the Office of Housing. Compliance date: January 1, 2027 today, announced to move to January 1, 2028. 

Agencies in this position should decide now whether to bring PBRA units to HOTMA voluntarily on the PIH schedule, using the TRACS rent override HUD has permitted, or to run both rule sets for a year. Either choice is defensible. Running two rule sets without a written procedure is not. 

What PHAs Should Do Now 

1. Confirm your compliance date. If you administer public housing, HCV, PBV, or Mod Rehab and you are not MTW or FRS-only, your date is January 1, 2027. Put it in writing to staff and the board this week so the 2028 headline does not create confusion. 
2. Check your reexamination calendar. Identify every annual reexamination with an effective date of January 1, 2027 or later. Those files are being worked now and must use HOTMA income and asset policies. If they are being processed under pre-HOTMA rules, stop and correct the workflow. 
3. Get a written answer from your software vendor. Ask two questions: when will the system produce the 2024 HUD-50058 for IMS/PIC, and if that date is after November 2026, when will it support the Appendix B alternative instructions? Do not accept a verbal answer. 
4. Finish the Administrative Plan and ACOP updates. Asset limits, self-certification, the medical deduction phase-in, interim reexamination triggers, and any permissive deductions all require adopted policy before they can be applied. Board approval takes time. Schedule it. 
5. Load the 2027 inflation-adjusted values. January 1, 2027-effective reexaminations must use HUD’s values for calendar year 2027: the $54,898 threshold for imputed asset income and asset self-certification, the 0.38 percent passbook rate, the $525 dependent deduction, the $575 elderly or disabled family deduction, and the $109,797 net family asset limitation. Confirm software configurations and staff reference materials use the 2027 values before January-effective files are completed. 
6. Train on the calculation, not just the rule. Staff need to work examples: when to impute, when not to, how the 5 percent hardship threshold applies at a family’s first post-HOTMA reexam, and how to file a non-interim update. The notice includes worked examples that make good training material. 
7. If you also hold PBRA, choose a path and document it. Decide whether PBRA units convert with PBV or wait for the Multifamily date, write the procedure, and brief property staff. 
8. Watch for two notices. The formal Office of Housing notice confirming 2028, and any PIH guidance on the MTW and FRS deadlines. Neither changes the January 1, 2027 date for standard PHAs. 

Where Does Your Agency Stand?

Most of the work between now and January 1 is knowing which of the eight steps above are already done, which are half done, and which have not started. Agencies that can answer that today control the next 90 days. Agencies that cannot will find out in January.

AMA’s C3 Rapid Risk Assessment is built for that question. It is a structured review of policy, process, and staff readiness that identifies compliance vulnerabilities and operational gaps before they become findings, and gives leadership a clear picture of what the January 1 transition requires.

When Additional Support May Make Sense 

The agencies most exposed by the January 1 date are not the ones that do not understand HOTMA. They are the ones whose staff are already carrying a full reexamination load and cannot absorb a policy rewrite, a software conversion, and a training cycle at the same time. 

AMA works with PHAs to complete HOTMA policy updates, review reexamination files against the new income and asset rules, and put a quality control process in place so the January 1 transition holds. If your agency is on the 120-day cycle and the September start caught it short, a short conversation is a good place to begin. 

This article is intended as general information and does not replace HUD regulations or official guidance.