HUD on Policy Implementation: Delay HOTMA; Support Coming for VAWA
(May 20, 2025) According to the U.S. Department of Housing and Urban Development (HUD), affordable housing providers should delay adjusting property procedures or rules to comply with the Housing Opportunity Through Modernization Act (HOTMA) until HUD issues new guidance.
While HOTMA compliance technically begins July 1, 2025, HUD is in the process of updating the compliance deadline. The agency plans to issue written guidance later in May that will establish a new compliance date. In the meantime, HUD is encouraging housing providers not to change processes before new guidance is issued. The agency provided the direction to LeadingAge following reports that some housing providers are readying for the July 1st compliance date by beginning to remove applicants from waitlists who would no longer be eligible for HUD-assisted Multifamily Housing under new HOTMA eligibility rules.
HOTMA is a major rule change in affordable housing that determines who can live in HUD-assisted housing and how much rent they pay. Learn more about HOTMA from LeadingAge here.
HUD is also in the process of translating forms and providing implementation support for requirements under the Violence Against Women Act (VAWA). Earlier this year, HUD published new VAWA forms that housing providers use to comply with the VAWA reauthorization, including expanded VAWA applicability to the Housing Trust Fund and Section 202 direct loan programs.
The VAWA is a federal law that provides protections for survivors of domestic violence, dating violence, sexual assault, and stalking, including housing protections for those living in federally subsidized housing. HUD requires covered housing providers to use HUD-approved VAWA forms, after customizing each form with their program-specific information where identified, to notify residents of their VAWA rights, create a model emergency transfer plan for residents, certify VAWA-related documentation, and establish emergency transfer requests.
The newly published forms (HUD-5380, HUD-5381, HUD-5382, and HUD-5383) replace the previously expired versions. HUD is in the process of translating the VAWA forms, but the agency has not given LeadingAge an expected timeline for the release of the translated forms. Later this year, HUD will issue a factsheet to assist housing providers with implementation of the VAWA forms and requirements. In the meantime, housing providers can reach out to HUD’s Office of Gender-Based Violence for technical assistance (ogbv@hud.gov).
In addition, LeadingAge has learned that the Trump administration is reviewing the VAWA materials to confirm that they align with presidential priorities, and further revisions may be released soon that impact the use of the forms by housing providers. More information is available from LeadingAge here.
Contact: Annalyse Komoroske Denio, akomoroskedenio@leadingageny.org, 518-867-8866