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
1. Decide whether your amendment is a significant amendment
Everything downstream of this page turns on the answer, and the answer is not HUD's to give. The criteria are the ones your own agency wrote into its Annual Plan. If your published criteria do not capture an amendment of this size, the participation machinery in 903.13, 903.15 and 903.17 is not triggered — and if they do, all of it is.
24 CFR 903.7(s)(2)(ii): “A PHA must identify the basic criteria the PHA will use for determining: (i) A substantial deviation from its 5-Year Plan; and (ii) A significant amendment or modification to its 5-Year Plan and Annual Plan.”
24 CFR 903.21(a) points at “§ 903.7(r)(2)” for this definition. That cross-reference is stale in the regulation itself: part 903 was re-lettered by later amendments and paragraph (r) of 903.7 is now the project-based assistance statement. The live definition is at (s)(2)(ii), verified against the current eCFR issue on 30 July 2026.
Read 24 CFR 903.7(s)(2)(ii) on eCFR
2. Consult the Resident Advisory Board, and write down what it said
The RAB's role covers amendments, not just the plan it was formed around. Two obligations run together here, and the second is the one that shows up in a file review: you must consider the recommendations, and you must submit a copy of them alongside a description of how you addressed them. A consultation with no paper trail reads, later, as no consultation.
24 CFR 903.13(a)(1) and (c)(1): “The role of the Resident Advisory Board (or Resident Advisory Boards) is to assist and make recommendations regarding the development of the PHA plan, and any significant amendment or modification to the PHA plan.”
903.13(c)(1) is the half agencies miss: “In submitting the final plan to HUD for approval, or any significant amendment or modification to the plan to HUD for approval, the PHA must include a copy of the recommendations made by the Resident Advisory Board or Boards and a description of the manner in which the PHA addressed these recommendations.”
Read 24 CFR 903.13(a)(1) on eCFR
3. Publish the notice and open the file for inspection — 45 days before the hearing
This is the clock that decides your board calendar, and it has two halves that have to happen together. The proposed amendment goes on the shelf at your principal office for public inspection during normal business hours, and a notice goes out saying it is there and when the hearing will be. Not one or the other. Both, 45 days before the hearing.
24 CFR 903.17(b): “Not later than 45 days before the public hearing is to take place, the PHA must: (1) Make the proposed PHA plan(s), the required attachments and documents related to the plans, and all information relevant to the public hearing to be conducted, available for inspection by the public at the principal office of the PHA during normal business hours; and (2) Publish a notice informing the public that the information is available for review and inspection, and that a public hearing will take place on the plan, and the date, time and location of the hearing.”
The clock on this step: 45 days before the public hearing.
Read 24 CFR 903.17(b) on eCFR
4. Hold the public hearing
The hearing belongs to the board, not to staff, and the location is a requirement rather than a courtesy: it has to be convenient to the residents the agency serves. 903.17(c) adds that the agency conducts reasonable outreach to encourage broad participation, which is a separate obligation from publishing the notice.
24 CFR 903.17(a): “The PHA's board of directors or similar governing body must conduct a public hearing to discuss the PHA plan (either the 5-Year Plan and/or Annual Plan, as applicable) and invite public comment on the plan(s). The hearing must be conducted at a location that is convenient to the residents served by the PHA.”
Read 24 CFR 903.17(a) on eCFR
5. Adopt it at a duly called board meeting open to the public
A significant amendment cannot be adopted by staff, by a committee, or by circulating a signature. It is adopted at a meeting of the governing body that was duly called and that the public may attend — which means the resolution, the minutes and the meeting notice are all part of the record the amendment rests on.
24 CFR 903.21(a)(1): “May not adopt the amendment or modification until the PHA has duly called a meeting of its board of directors (or similar governing body) and the meeting, at which the amendment or modification is adopted, is open to the public;”
903.21(b) puts the whole chain in one sentence: “Each significant amendment or modification to a plan submitted to HUD is subject to the requirements of §§ 903.13, 903.15, and 903.17.”
Read 24 CFR 903.21(a)(1) on eCFR
6. Submit it — then wait before implementing
Adoption is not the finish line. A significant amendment may not be implemented until it has been submitted to HUD and approved. HUD then has 75 days, and its silence counts: if no notice of disapproval arrives by the 75th day the amendment is treated as approved. That deemed-approval rule is the one exception a troubled PHA cannot use — a troubled agency needs HUD's written notice either way.
24 CFR 903.21(a)(2) and 903.23(c)(3): “If HUD fails to issue the notice of disapproval on or before the 75th day after the date on which the PHA submits its plan or significant amendment or modification to the plan, HUD shall be considered to have determined that all elements or components of the plan required to be submitted and that were submitted, and to be reviewed by HUD were in compliance with applicable requirements and the plan has been approved.”
The clock on this step: up to 75 days after submission.
The troubled-PHA carve-out at 903.23(c)(4) reads “The provisions of paragraph (b)(3) of this section do not apply to troubled PHAs” — another cross-reference the re-lettering left behind, since the deemed-approval rule now sits at (c)(3). Verified against the current eCFR issue on 30 July 2026.
Read 24 CFR 903.21(a)(2) on eCFR
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 still in play. 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. Published notice by about 3 September 2026 leaves that chain intact. 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.
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