The HOTMA adoption timeline

Deciding your HOTMA elections is the part everybody plans for. Getting them adopted is the part that has a deadline, and the deadline is not the one on HUD’s notice — it is the one your own board calendar imposes once you count backwards through the participation rules in 24 CFR part 903.

This page walks the six procedural steps in order, each with the section it comes from and the regulation’s own words. It is the process the paid adoption pack produces documents for; here it is with the drafting removed.

Before anything else: this may not apply to you

HUD Notice PIH 2026-15 exempts two populations — Moving to Work demonstration agencies, and PHAs that submit Form HUD-50058 exclusively through HUD’s Family Reporting Software. Neither is settleable from any file HUD publishes: there is no FRS roster at all, and HUD’s MTW layer has not been updated since 2018, so it misses the later expansion cohorts.

So we do not tell you the deadline applies to your agency. Unless your agency is in MTW or files exclusively through FRS, HUD begins enforcing sections 102 and 104 on 1 January 2027 — and PIH 2026-15 puts an earlier date on the operational work: “PHAs who begin annual reexaminations 120 days prior to the effective date of the reexamination will need to begin using HOTMA policies to collect and verify family income beginning in September 2026.”

There is a second gate, and it is the first step below rather than a footnote. Everything on this page is triggered by the amendment being a significant amendment — and whether it is one is decided by criteria your own agency published, not by HUD and not by us. An amendment your published criteria do not reach skips the participation chain entirely.

The 6 steps, in order

Counting backwards: two dates HUD does not publish

Two of the six steps carry fixed periods — 45 days of public notice before the hearing under 903.17(b), and up to 75 days of HUD review after submission under 903.23(c)(3). Chain them and the arithmetic produces dates that are nowhere in any HUD notice, because they are a consequence of the rules rather than a publication. Both figures below are ours, worked from the two quoted periods. Check them against your own fiscal year and your own board meeting schedule before you rely on either.

The first has already gone, and it went quietly. Because 903.17(b) puts a full 45 days between publishing the notice and holding the hearing, an agency that has not published one yet cannot reach a hearing before the second half of September 2026 — after the September 2026 reexamination work PIH 2026-15 describes has already begun. There is no version of the significant-amendment path that gets an agency starting now to the September operational date, and any vendor telling you otherwise is not counting. The honest plan is the January one.

The second is the one that closes on 3 September 2026. For the amendment to be implementable on 1 January 2027 without depending on HUD acting early, the 75-day review has to be running by 18 October 2026 — so submission and board adoption sit on or before that date, the hearing before the board meeting, and the 45-day notice roughly 45 days before the hearing. That puts the last publishable notice date at about 3 September 2026. Publish on or before it and the chain holds. Publish after it and the January path stops being reachable through the significant-amendment route at all, because the 45 days and the 75 days no longer both fit before 1 January — what is left is HUD choosing to act before the 75th day, which is not something to plan a board calendar around. A troubled PHA cannot lean on the deemed-approval rule at all and should treat 18 October as early rather than sufficient.

That is the whole reason this product exists as a flat fee rather than an hourly engagement. The drafting is not the hard part of a HOTMA amendment; the sequence is, and the sequence is unforgiving about order.

What the record ends up containing

Walked properly, the six steps leave behind a specific set of paper: the redlined chapter carrying your elections with their citations, the record of which election the agency made and why, the published 45-day notice, the Resident Advisory Board consultation memo with the recommendations and your response to them, the hearing script, the board resolution, and a dated adoption memo tying the sequence together. Those are the documents an adoption pack is, and the reason they travel together is that no one of them proves adoption on its own.

Where this comes from

Every quotation above was fetched from the Electronic Code of Federal Regulations and is verbatim. Source edition: eCFR title 24, chapter IX, part 903, current issue as of 30 July 2026. Catalogue version 2026-07-30.

Two of the cross-references inside part 903 are stale, and this page follows the live paragraph rather than the pointer: 903.21(a) sends you to “§ 903.7(r)(2)” for the significant-amendment definition, which now sits at 903.7(s)(2)(ii), and 903.23(c)(4) excludes troubled PHAs from “paragraph (b)(3)”, which is now (c)(3). Both were checked against the current eCFR issue of title 24 on 30 July 2026. We note them because an agency reading the pointer instead of the paragraph ends up citing a project-based assistance statement in a HOTMA amendment.

QuorumFile is not affiliated with HUD, with any HUD field office, or with your Resident Advisory Board, and nothing on this page is legal advice. Your state and local open-meetings law sits on top of 903.21 and may require more notice than the federal rule does — this page covers the federal floor only.

Which elections does my agency have to record?

Enter your HUD participant code and the free Decision Sheet scopes the election catalogue to the programs HUD records you as running, flags the ones that require a written policy, and prints each with its citation. It asks the MTW and FRS questions before it computes anything. No payment, and no account.