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HOTMA Updates: Revisions to Tenant Selection Plans and Enterprise Income Verification Policies

February 17, 2026 11:30 AM EST 60 Minutes

Presented By: Keith Warwick

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Description

The compliance deadline for the Housing Opportunity Through Modernization Act (HOTMA) has been extended to January 1, 2027. HOTMA was enacted to create greater consistency, efficiency, and clarity across housing programs administered by the U.S. Department of Housing and Urban Development (HUD). Its intent is to modernize administrative processes, simplify documentation requirements, and streamline program rules for households eligible for housing assistance.

This webinar provides a detailed review of HOTMA-related Enterprise Income Verification (EIV) Policies and Procedures and Tenant Selection Plans (TSP), with a focus on statutory changes and updated HUD guidance. Participants will be walked through HUD Notice H 2023–10 and related materials, with clear explanations of revised income and asset thresholds, updated reporting obligations, new verification standards, available asset limitation options, and interim reexamination requirements.

Special attention will be given to how housing providers can properly prepare and align their policies with HOTMA while avoiding premature or incorrect system implementation. HUD has formally extended the HOTMA compliance deadline from January 1, 2026, to January 1, 2027, making full Compliance with the final rule mandatory as of that date.

Owners participating in HUD Multifamily Project-Based Rental Assistance (PBRA) programs will be able to meet HOTMA requirements through the use of the rent override function within the Tenant Rental Assistance Certification System (TRACS). Until HOTMA is fully implemented, owners are required to continue following their existing Tenant Selection Plans (TSP) and Enterprise Income Verification (EIV) policies and procedures.The session will also cover additional key elements of HOTMA, which was created to simplify the administration of low-income housing programs, including the Section 8 voucher program, primarily overseen by HUD. While HOTMA was phased in between 2017 and 2023, and initially targeted for full implementation by January 1, 2024, HUD extended the final compliance date to January 1, 2027, to improve program management.

Under HOTMA, asset limits were increased, income calculation methods were revised, and administrative processes were streamlined. One major component of HOTMA is the National Standards for the Physical Inspection of Real Estate (NSPIRE), which introduces more stringent inspection requirements for safety-related building features. These include smoke and carbon monoxide detectors, HVAC systems, ground fault circuit interrupters (GFCI), pest control, and health concerns related to mold.

NSPIRE establishes four deficiency categories—life-threatening, severe, moderate, and low-risk—based on immediate and long-term health and safety impacts. Life-threatening issues must be corrected within 24 hours, severe and moderate deficiencies within 30 days, and low-risk items within 60 days. Property owners and investors must understand inspection frequency, inspection scope, and required pre-inspection repairs to avoid unnecessary expenses.

NSPIRE also introduces a new inspection scoring system, beginning with 100 points per property. Points are deducted for identified deficiencies. A score below 60 constitutes a failed inspection, while a score below 30 may result in HUD enforcement actions. The updated inspection model prioritizes tenant health, safety, and habitability. Under NSPIRE, Section 8–eligible homeowners must conduct annual self-inspections of all living units to confirm continued suitability.

This webinar will also examine the Real Estate Assessment Center (REAC) inspection protocols currently used by HUD to assess low-income housing. Originally developed in the late 1990s, REAC focused on physical condition, appearance, and maintenance costs. NSPIRE replaces and consolidates Housing Quality Standards (HQS) and Uniform Physical Condition Standards (UPCS) into a single inspection framework with a stronger emphasis on tenant safety and living conditions.

NSPIRE requires HUD inspectors, Public Housing Authorities (PHAs), and low-income property owners to respond to tenant-initiated inspection requests when deficiencies are reported. This tenant-driven inspection process strengthens the overall effectiveness of NSPIRE and improves inspection outcomes. The webinar will outline the steps tenants must follow to request a non-routine inspection.

HOTMA significantly alters how multifamily owners and agents manage income certifications, EIV utilization, asset limits, interim reexaminations, and Tenant Selection Plans. Although HUD has delayed system readiness through TRACS 203A and new model leases, required updates to EIV Policies and Procedures and Tenant Selection Plans are already in effect. Owners who do not correctly revise their policies risk Management and Occupancy Review (MOR) findings, inconsistent file documentation, fair housing violations, and incorrect subsidy calculations. HOTMA, a federal law enacted in 2016, is administered by HUD to modernize low-income housing programs, including housing developments and Section 8 voucher assistance. Implementation occurred gradually from 2017 to 2023, culminating in the publication of the final rule in 2023 with an initial effective date of January 1, 2024. That deadline was subsequently extended to January 1, 2027. HOTMA raised asset thresholds, revised income calculations, and reshaped inspection protocols. NSPIRE replaced older REAC components to better address tenant safety and housing quality.

Learning Objectives:-

  • Introduction to the Housing Opportunity Through Modernization Act
  • Overview of HOTMA, EIV, and TSP history and January 1, 2027, implementation
  • Updated EIV procedures
  • Revised Tenant Selection Plan requirements
  • Seismic, wind, and structural forces affecting buildings
  • HUD Notice H 2023–10
  • Threshold and reporting requirements
  • Verification standards
  • Asset evaluation rules
  • Related housing regulations for 2025–2026
  • Section 8 voucher program overview
  • NSPIRE inspection standards
  • Tenant Rental Assistance Certification System (TRACS)
  • HUD Notice H 2023–10
  • Related low-income housing regulations for 2025–2026.

Areas Covered:-

  • Become familiar with updated EIV procedures
  • Understand revised TSP requirements
  • Recognize forces affecting building structures
  • Review HUD Notice H 2023–10
  • Understand reporting thresholds
  • Learn verification processes
  • Gain awareness of additional HOTMA provisions
  • Understand asset review rules
  • Review applicable 2025–2026 housing regulations
  • Understand the Section 8 voucher program
  • Learn the NSPIRE inspection requirements.

Why Should You Attend?

HOTMA compliance is an active and ongoing requirement. HUD expects housing providers to maintain updated EIV and TSP documentation that accurately reflects HOTMA regulations, discretionary options available to owners, and enforcement timelines. This webinar helps participants avoid common compliance errors, including improper asset limit enforcement, incorrect handling of interim reexaminations, misuse of EIV reports, and policy conflicts with fair housing and civil rights standards.

HUD: Leadership teams, architects, engineers, purchasing agents, and inspectors must understand inspection criteria and scoring standards.

PHA (Public Housing Authorities): PHAs must educate tenants regarding updated rights under NSPIRE and revised EIV and TSP procedures.

TENANTS: Tenants will gain an understanding of their inspection rights, participation opportunities, and methods for reporting deficiencies. They will learn how inspections are scored and how to Identify serious health and safety concerns.

INVESTORS: Property owners renting to Section 8 participants must prepare for potential safety-related capital improvements. Understanding inspection schedules, inspection scope, and deficiency remediation timelines is essential to minimizing financial exposure from lost rent, repairs, and extended vacancies.

Who Will Benefit?

  • Architects
  • Building inspectors
  • Civil and structural engineers
  • Counselors
  • Firefighters
  • General contractors
  • Health department personnel
  • HUD inspectors
  • Lenders
  • Maintenance personnel
  • Municipal social service agencies
  • Psychologists
  • Real estate investors
  • Real estate brokers
  • Social workers
  • Sociologists
  • State OSHA offices
  • Tenant rights attorneys.

Keith Warwick

Know Your Presenter

EDUCATION: - Bachelor of Science in Civil Engineering, University of California at Davis LICENSES: • California: Professional Civil Engineer • Illinois: Professional Engineer • New York: Professional Engineer ENGINEERING EXPERIENCE: • Owner, WARWICK EDUCATION AND TRAINING (2025–present) o Webinars o Writing • Owner, PATTY & KEITH INC. (2011–2023) o Civil engineering o Real estate due diligence o Site assessments • Civil Engineer, Federal Government (1988–2011) o Structural evaluations o Environmental, safety, and health o Civil engineering INSTRUCTOR EXPERIENCE: • Oakton and Kankakee Colleges: Civil Engineering (2025–present) • LORMAN: Civil Engineering (2019–present) • Edumind/School of P.E.: Exam preparation (2015–present) • University of Washington: Construction Management (2017) • Yuba College: Civil Engineering (2015–2016)