March 7, 2024

Updated HOTMA Implementation Guidance 

In January 2024, HUD adjusted the HOTMA implementation guidance by releasing a revised version of the joint Multifamily Housing (MFH) and Public and Indian Housing (PIH) notice originally released last September. The updated notice may be found HERE.

This document outlines items affecting the LIHTC, HOME, and NHTF programs. This information is used with the permission of Costello Compliance. 

OHFA Forms and Guidance

OHFA has received several inquiries as to when our forms and Tenant Income Certification (TIC) will be HOTMA compliant. We are working on these documents with an expected publishing date in the next several months. When published, industry partners may begin using these forms and updated TIC. Use of the updated forms and TIC will not be mandatory until January 1, 2025, however if the updated forms and TIC are used prior to January 1, 2025, OHFA will still require one of the following actions: 

• If an owner decides to implement some of the HOTMA rules (i.e., hybrid approach) regarding income and asset calculations (Section 102 of HOTMA) prior to January 1, 2025, an OHFA clarification record must be placed in the tenant file explaining which parts of the HOTMA rule were used to certify the tenant. 
• If an owner decides to implement all of the HOTMA rules prior to January 1, 2025, an OHFA clarification record must be placed in the tenant file stating certification was conducted using HOTMA rules.  

Importantly, OHFA will not enforce HOTMA-related file errors (i.e., will not issue 8823s) discovered prior to January 1, 2025.

HUD Extension for TSPs and EIV Policies and Procedures

HUD's 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 Plans (TSPs) and Enterprise Income Verifications (EIVs) policies and procedures from March 31 to May 31, 2024. This guidance is applicable to owners of HUD Multifamily Housing Programs (Section 8 PBRA, Section 202, 811) and HUD Public Indian Housing (Public Housing, Housing Choice Vouchers, Project-based Vouchers). Here is a helpful link of the HUD mandated updates: MFH List of Discretionary Policies to Implement HOTMA.

Note the HOTMA mandated TSP updates do not apply to LIHTC-, HOME-. or NHTF-funded projects. While owners of these projects must have TSPs per OHFA’s Tenant Selection Plan Guidelines, HOTMA updates are not required to be incorporated into them.

Reminder: OHFA’s Acquisition and Rehabilitation Training Is Now Available On-demand!

OHFA has suspended offering live training webinars, but owners/management agents can take advantage of the recorded Acquisition and Rehabilitation Training, which is now on-demand. The course, which is co-presented with Melanie Shapiro (Ohio Capital Corporation for Housing), focuses on the complexities of qualifying households, transfers, starting and maximizing credits, resyndications, and best practices. 

Continuing education credits (CEUs) will not be offered and attendance certificates will not be issued. However, watching this training at your leisure not only provides a good refresher but also benefits those who are new to the industry. The course manual may be found here.

New OHFA Compliance Staff

OHFA is pleased to announce two new program compliance managers to our team. 

James Kohlberg

Kellie Wolfe

James comes to OHFA from the city of Columbus where he was the property maintenance and inspection supervisor.

Kellie recently worked at Wallick Communities, where she was a regional manager. She managed 16 communities with HOME and tax credit allocations. 

Stay Informed! 

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