CARH’s BROADCAST EMAIL—Regulatory Alert 

August 22, 2024

Today, Rural Development published an Unnumbered Letter (UL) dated August 19, 2024, entitled, “Housing Opportunity Through Modernization Act (HOTMA).” The UL provides an overview of HOTMA tenant income and asset calculation changes and the projected timeline for those changes.

Effective January 1, 2025, all tenant certifications must implement the changes outlined in the UL (and the Frequently Asked Questions included in the UL). This means that every tenant is NOT expected to be recertified by January 1, 2025. Instead, new move-ins with tenant certifications effective January 1, 2025, or later will follow the HOTMA regulations and tenant recertifications that are effective January 1, 2025, or later will follow HOTMA regulations. Prior to January 1, 2025, RD will not penalize multifamily owners for HOTMA-related tenant file errors during Supervisory reviews.

In October 2024, RD is expected to publish a new Form RD 3560-8 Tenant Certification that must be used for all tenant certifications with an effective date of January 1, 2025, or later. RD will also update Handbook HB-2-3560 to reflect the HOTMA changes found in 24 CFR 5.609(a) and (b) and 24 CFR 5.611.

For other news and information affecting the affordable rural housing industry, please visit the Newsroom on CARH’s website, www.carh.org.