News

HOTMA Sections 102 and 104 Compliance Deadline Extended for CPD Programs

By: Steven Molinari, Policy Analyst

January 5, 2026 — On December 30, 2025, HUD published a notice in the Federal Register once again extending the deadline for compliance of Sections 102 and 104 of the Housing Opportunity Through Modernization Act of 2016 (HOTMA) for Community Planning and Development (CPD) programs to January 1, 2027.

This extension applies to the following programs:

  • HOME Investment Partnerships program (HOME);
  • HOME-American Rescue Plan (HOME-ARP);
  • Housing Trust Fund (HTF);
  • Housing Opportunities for Persons With AIDS (HOPWA);
  • Community Development Block Grant program (CDBG);
  • Emergency Solution Grants (ESG);
  • Continuum of Care (CoC) program; and
  • CPD programs funded through competitive processes.

The notice states, that HUD will still be permitting CPD grantees the choice to implement applicable income safe harbors. The notice also mentions that while the extension is in effect, grantees and project owners may continue to adhere to regulations as they existed prior to January 1, 2024.

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