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© Copyright 2025 Nan McKay & Associates Adminplan 2/1/25 <br />Unlimited copies may be made for internal use Appendix-1 <br />HOTMA 102/104 Appendix to the <br />Administrative Plan <br />Purpose of the Appendix <br />HUD published a final rule on February 14, 2023, revising regulations related to income, assets, <br />adjusted income, verification, and reexams (among others) to implement Sections 102 and 104 of <br />HOTMA. While the new regulations were effective January 1, 2024, HUD has delayed the full <br />compliance date for HOTMA 102/104. Initially, Compliance with Sections 102 and 104 of <br />HOTMA means not only applying HOTMA 102/104 regulations to affected programs but also <br />reporting in HUD’s new Housing Information Portal (HIP) system. Currently, PHAs remain <br />unable to fully comply with HOTMA 102/104 because compliance depends on transitioning <br />from HUD’s IMS/PIC system (which is unable to accept HOTMA-compliant Form HUD-50058) <br />to HUD’s new HIP system (which will be the only system that accepts HOTMA-compliant Form <br />HUD-50058). PHAs cannot transition to HOTMA until HIP is in place, HOTMA-compliant, and <br />accessible. <br />On December 18, 2024, HUD published Notice PIH 2024-38, which identifies provisions in <br />HOTMA 102/104 that PHAs must comply with no later than July 1, 2025. The notice states that <br />all transactions with an effective date on or after July 1, 2025, must be processed using <br />requirements in the notice. The July 1, 2025, compliance deadline does not apply to other <br />HOTMA 102/104 provisions not listed in the notice. Other provisions are still dependent on HIP <br />implementation and may not be implemented yet. <br />The PHA must: <br /> Have stopped enrolling families into the EID as of 12/31/23; <br /> Transition to the new Form HUD-9886-A no later than 2/1/25; <br /> Apply HOTMA 102/104 income exclusions listed in 24 CFR 5.609(b) (including new <br />requirements for student financial assistance) for all income examinations effective on or <br />after 7/1/25; <br /> Apply provisions related to de minimis errors; and <br /> Use these new HOTMA 102/104 definitions listed in the regulations for all transactions <br />effective on or after 7/1/25. <br />EXHIBIT 1