LeadingAge Comments on HUD HOTMA Drafts

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In response to draft materials posted for public comment in September, LeadingAge called on HUD to fix errors, provide a more realistic timeline, and modernize approaches to housing forms.

LeadingAge submitted comments on October 17, 2025, to the Department of Housing and Urban Development (HUD) in response to draft leases, forms, and resident brochures that the agency has released for public input. Updated by HUD to comply with new requirements under the Housing Opportunity Through Modernization Act (HOTMA), the materials were posted for comment on September 17.

LeadingAge worked with members to review many of the documents, including the model lease that HUD requires affordable senior housing providers to use, the Resident Rights and Responsibilities (RRR) brochure, the factsheets for the Section 8 and Section 202 programs, and certain notices and forms that housing providers use for their HUD-assisted housing program compliance.

Throughout our comments, we emphasize the need to better address discretionary options under HOTMA, which are currently presented in confusing or incomplete ways throughout the documents and materials.

LeadingAge also requests that HUD correct certain items that are out of alignment with either current policy or other updated forms.

Lastly, we ask HUD to communicate more clearly and with more specificity, to take the opportunity to build in additional modernizations, and to give everyone more time to adjust to HOTMA requirements.

Updating the materials brings HUD one big step forward to HOTMA implementation, which, though currently scheduled for January 1, 2026, is expected to be postponed again because the agency has not finalized all the HOTMA-compliant materials and software.

View our comments on HOTMA-compliant forms here, and keep up with our HOTMA updates here.