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Pre-HOTMA or HOTMA...

Use this table to determine whether to use Pre-HOTMA or HOTMA forms based on Tenant Certification Date.

What is the tenant certification effective date? Is this tenant certification effective before or after my property implemented HOTMA? Guidance and forms to use for this tenant certification
Prior to January 1, 2024 N/A
  • Pre-HOTMA rules apply
  • Must use pre-HOTMA Program Compliance Manual and pre-HOTMA forms
Between January 1, 2024 and December 31, 2025 Before my property implemented any aspects of HOTMA
  • Pre-HOTMA rules apply
  • Must use pre-HOTMA Program Compliance Manual and pre-HOTMA forms
Between January 1, 2024 and December 31, 2025 After my property implemented some but not all aspects of HOTMA
  • Owners/agents must document the tenant file to show which aspects of HOTMA were implemented on which date.
  • Which Program Compliance Manual, rules, and forms to use will depend on the information above.
Between January 1, 2024 and December 31, 2025 After my property implemented all aspects of HOTMA
  • HOTMA rules apply
  • Must use HOTMA Program Compliance Manual and HOTMA forms
  • Owners/agents must keep a written record of the date they implemented HOTMA to be provided upon request.
On or after January 1, 2026 N/A
  • HOTMA rules apply
  • Must use HOTMA Program Compliance Manual and HOTMA forms