HOTMA Implementation Guide: What Property Managers Need to Know in 2025

The Housing Opportunity Through Modernization Act (HOTMA) of 2016 made the most significant changes to HUD-assisted housing programs in decades. With the final implementation rules now in effect, affordable housing professionals must understand these critical changes.

Key HOTMA Changes You Need to Know

Income Calculation Changes (Section 102)

HOTMA Section 102 revises income definitions and calculations for HUD programs. Key changes include:

  • New treatment of assets and income from assets
  • Revised earned income disallowances
  • Updated self-employment income calculations
  • New provisions for mixed-family households

Program Eligibility Changes (Section 104)

Section 104 modifies over-income family policies and establishes new procedures for:

  • Identifying over-income families
  • Required actions when families exceed income limits
  • Termination procedures and timeframes
  • Hardship provisions for families near the income limit

Compliance Action Items for Property Managers

Property managers should immediately:

  1. Review and update income calculation procedures
  2. Retrain all staff on new income definitions
  3. Update lease agreements to reflect HOTMA changes
  4. Implement new over-income monitoring procedures
  5. Update tenant files and software systems
Get expert guidance on HOTMA compliance: HOTMA 102 & 104: Turning New Rules into Real-World Practice

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