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Implementation
Funding Agreements
OHFA will retroactively apply the 2025 HOME Final Rule to all HOME projects. HOME agreements completed prior to April 20, 2025, will not be amended.
Tenant Protections
For HOME projects allocated funding on/after April 20, 2025, HUD will create and require three lease addendums for the HOME program — one for each type of HOME rental activity (e.g., rental housing, tenant-based rental assistance, security deposit assistance only.
- HUD delayed the effective date of new tenant protections to October 30, 2025.
- New tenant protections do not apply to HOME projects allocated funds prior to April 20, 2025, unless and until HUD issues guidance allowing tenant protections to be retroactively applied.
Rents
Low-Income Housing Tax Credit (LIHTC) rents are acceptable for Low HOME Rent Limit units. This removes the Low HOME Rent Limit cap on units that are also funded by LIHTCs.
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When a household receives rental assistance — whether tenant- or project-based — another program’s mandated rent is acceptable for HOME (i.e., up to the payment standard for subsidized units). The HOME Low and High rent limits do not apply, which is an improvement over the proposed rules that would have required the tenant portion of rent to be capped at the HOME rent limits.
- Rent-increase notices must be provided 60 days in advance of an increase.
Utility Allowance (UA)
The 2025 HOME Final Rule reinstates the public housing authority (PHA) UA option. HUD will now allow the PHA UA option to be used for all HOME projects. Owners/management agents can also use an Engineer’s Energy Consumption Model, Estimates, HUD Utility Model, and Renewable Energy Source. OHFA will revise its current UA policy to incorporate the 2025 HOME Final Rule UA provisions in the next couple of weeks.
Fees
OHFA does not permit owners/management agents to charge tenant fees that are prohibited by HOME regulations. For a fee to be allowable, it must be reasonable, customary, and approved by OHFA.
File Audits
OHFA will not take any file enforcement action for violations of the 2025 HOME Final Rule until after April 20, 2026.
- Prior to April 20, 2026, OHFA will note any file violation of the 2025 HOME Final Rule in the compliance audit report. Owners/management agents are required to correct the findings.
Inspections
HUD adopted NSPIRE protocols for HOME units.
- OHFA will allow the use of NSPIRE-based inspection reports (i.e., REAC) as long as the associated inspection occurred within the past 12 months. The only exception is OHFA must conduct the initial inspection within 12 months after project completion.
Means-Tested or Safe Harbor Verifications
OHFA will allow means-tested determination of income for HOME units for all certifications throughout the period of affordability, including the initial certification.
Importantly, the use of means-tested income determination is optional for owners/management agents; it is not required.
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