HOTMA policy updates for HUD multifamily owners and management agents

Your policies were due in 2024. Full HOTMA compliance is due in 2027.

HUD Notice H 2024-04 required covered multifamily owners to update their TSP and EIV policies and procedures by May 31, 2024, and make the revised TSP publicly available.

Notice H 2025-07 subsequently extended the deadline for full HOTMA compliance to certifications effective January 1, 2027 or later.

These are separate requirements. Owners must have their policies updated, but must also follow HUD's implementation instructions before applying the new HOTMA rules to tenant certifications.

Updated your policies in 2024? They may still need attention.

HUD has revised its implementation guidance since the original policy-update deadline.

In April 2026, Notice H 2026-05 replaced Attachment I of Notice H 2023-10, which sets the interim reexamination standards when household members are added or removed, including a limited exception tied to an owner's written policy.

HUD has also published the inflation-adjusted figures effective January 1, 2027:

• $109,797 net family asset limitation for applicable Section 8 PBRA and Section 202/8 programs
• $54,898 threshold used for asset self-certification, imputed asset income, and non-necessary personal property
• $525 dependent deduction
• $575 elderly or disabled family deduction
• 0.38% passbook savings rate

These amounts apply according to the property's program requirements and HOTMA implementation status. The asset limitation does not apply to every HUD multifamily program.

If your policies already reference HUD's annually adjusted amounts, those provisions may not need rewriting. If they contain older fixed figures, outdated requirements, or unresolved owner choices, Sonder identifies the specific sections that need attention.

The policy review: $500

Find out what needs to change before paying for a rewrite.

Send your TSP and EIV policies and procedures. Sonder compares the applicable provisions against HUD's multifamily HOTMA guidance, including:

• Notice H 2023-10 and its attachments, as amended by Notice H 2026-05
• HUD's Multifamily List of Discretionary Policies to Implement HOTMA
• Notice H 2024-04, Notice H 2025-07, and Notice H 2026-05
• HUD's multifamily HOTMA FAQs and published CY2027 inflation adjustments

The review covers applicable HOTMA policy requirements, including asset and income determinations, verification procedures, EIV usage, interim reexaminations, hardship provisions, and discretionary owner decisions.

Each provision is identified as Present, Outdated, Missing, Unclear, or Not addressed. Optional policy choices are identified separately from required provisions.

For each item requiring attention, the report includes the existing language and page reference where available, the issue identified, and its supporting HUD citation. Missing provisions are clearly flagged.

Within three business days of receiving your documents and payment or accepted purchase order, you receive a PDF report and editable findings file.

If you proceed with the rewrite, the full $500 review fee is credited toward it.

The rewrite: your existing policies, updated

$1,500 for one property's TSP and EIV policies and procedures.

Sonder writes the necessary HOTMA revisions directly into the documents you already use.

Your numbering, structure, and policies unaffected by HOTMA stay intact. Where HUD requires an owner to make a discretionary choice, Sonder identifies the decision and incorporates your approved selection rather than making it for you.

The result:

• Clean updated documents for owner review and approval
• Redlined copies showing the changes made
• Applicable HUD citations supporting the revisions
• A revised TSP that can be made publicly available following owner approval

The rewrite includes the underlying HOTMA policy review. You do not need to purchase the $500 review separately.

Delivery is within ten business days of receiving the required documents and payment or accepted purchase order.

Managing several properties?

If your properties share EIV procedures or use a common TSP structure, Sonder can update the shared language once and apply the relevant changes to each property's documents.

Each additional property is $300, because the shared EIV procedures and common plan language are updated once.

Straightforward pricing

The $500 review is credited toward the rewrite. If you start with the review, the remaining rewrite cost is $1,000.

Purchase orders, checks, ACH, and card payments are accepted. Sonder can provide a formal quote, W-9, and vendor setup paperwork.

How it works

1. Request the service. Order the policy review or request a quote for the full rewrite.
2. Send your documents. Provide your current TSP, EIV policies and procedures, and the HUD assistance program associated with the property. Word files are preferred; PDFs are accepted. No tenant files, EIV reports, or system credentials are needed.
3. Receive the work. A findings report within three business days, or updated policies and a redline within ten business days, once the documents and payment or accepted purchase order are received.
4. Review and approve. Your owner or authorized management team reviews the completed documents and confirms any policy selections before adoption or implementation.

Built for owners and agents without a dedicated policy department

Your staff already have recertifications, occupancy requirements, property operations, and HUD reporting to manage.

Comparing your policies against multiple HUD notices should not have to become another project on their desk.

Sonder handles the document comparison and drafting, identifies the decisions that require your attention, and gives you updated policies that follow the structure you already use.