multifamily program compliance updates

• CHFA Multifamily Program Compliance HOTMA Implementation Date Update
• Introduction to Compliance Fundamentals for Housing Tax Credits On-demand Webinar Updated for HOTMA
• 2026 Social Security COLA
• 2026 Annual Owner Certification (AOC) Due by February 15th
• 2026 Annual Submissions Reminder Summary

CHFA Multifamily Program Compliance HOTMA Implementation Date Update

The Housing Opportunity Through Modernization Act (HOTMA) was signed into law in July 2016, and makes significant changes to how annual income, including income from assets and student financial assistance, is determined for the Housing Tax Credit (HTC) and CHFA Loan programs. HUD has extended its full compliance date from January 1, 2026, and full implementation is now mandatory for all developments no later than January 1, 2027.

At this point, CHFA strongly encourages full implementation of all aspects of HOTMA (including all forms and rules) for all Housing Tax Credit and CHFA Loan developments not layered with Section 8, HOME, or comparable programs. Prior to January 1, 2027, noncompliance findings will not be issued for HOTMA-related tenant file errors during Program Compliance reviews. Instead, the Program Compliance Officer (PCO) will issue observations. CHFA recommends obtaining training as soon as possible to ensure management is ready to fully implement HOTMA on January 1, 2027.

As always, please contact your Program Compliance Officer with any compliance-related questions for the HTC and CHFA Loan programs. To find your PCO, search on CHFA’s website by city and property name.

Introduction to Compliance Fundamentals for Housing Tax Credits On-demand Webinar Updated for HOTMA

The CHFA “Introduction to Compliance Fundamentals for Housing Tax Credits,” previously called “The ABCs of LIHTC,” presents topics related to HTC compliance in Colorado. This training has now been updated for HOTMA and covers topics including:

• an overview of the HTC program, also known as Low Income Housing Tax Credit or LIHTC;
• occupancy requirements for HTC developments in Colorado, including verifications of income and assets;
• requirements for preparing Tenant Income Certifications;
• other compliance rules, including the IRS Student Rule;
• gross rent, utilities, and fees;
• other compliance requirements, including NextGen occupancy data; and resources.

Register for the Compliance Fundamentals class or email chfareach@chfainfo.com for inquiries and support.

2026 Social Security COLA Announced on October 24, 2025

The Social Security Administration announced there will be a 2.8 percent cost-of-living (COLA) increase for Social Security and Supplemental Security Income (SSI) benefits in 2026. For developments with Housing Tax Credits and/or CHFA loans, managers must factor in the COLA when estimating annual household income for move-in certifications effective after October 24, 2025.

If you have already prepared move-in certifications effective any time after the announcement, go back and review all estimates of Social Security income, apply the COLA, and recalculate household income. Since this is a known increase in 2026 income, the COLA must be reflected on all move-in Tenant Income Certification (TIC) forms effective after October 24, 2025. If an applicant has not yet received confirmation of their 2026 benefit, you can multiply the 2025 benefit amount by 1.028 to estimate the 2026 benefit.

For Social Security benefits, the increase will begin with the January 2026 payment. The COLA will also affect SSI, VA pensions, Civil Service Pensions, and Railroad Retirement. For SSI benefits, the increase began on December 30, 2025.

2026 Annual Owner Certification (AOC) Due by February 15th

Submissions available only through Insight.

CHFA requires that Annual Owner Certifications (AOCs) for the Housing Tax Credit and CHFA multifamily loan programs be submitted directly within Insight, which requires Owner registration to electronically submit and sign. This year’s AOC and updated Insight User’s Guide are available in Insight now – please sign into your Insight account to ensure your account is active. If you do not already have an Insight account, request a new user account from the Insight login page.

For more information about the AOC submission process and instructions on how to upload other required submissions to CHFA in Insight, we recommend that you view the Insight – Annual Submissions Overview training.

2026 Annual Submissions Reminder Summary

2026 annual submissions for the Housing Tax Credit and CHFA Multifamily Loan programs are due as follows. With the exception of fees, all submissions are due online in Insight or NextGen. For details, see CHFA’s Multifamily Program Compliance Manual, Chapter 3.