By Ian Georgiev, Policy Associate
Ian Georgiev is Policy Associate specializing in housing policy. Previously, he served as a Legislative Intern for Rep. Warren Davidson, focusing on financial services policy, and interned at Brownstein Hyatt Farber Schreck and Invariant, where he built relationships with Fortune 500 companies and foreign governments.
The U.S. Department of Housing and Urban Development issued a final rule on October 22, 2025 titled HOME Investment Partnerships Program: Further Program Updates and Streamlining. The rule does not change the HOME program itself but delays the implementation of two significant provisions from the broader January 2025 HOME Final Rule until April 30, 2026. These provisions involve updates to maximum per-unit subsidy limits and new renter protection requirements. HUD stated that the additional time is meant to give state and local housing agencies, developers and housing providers room to adjust their operations and financial planning before the new standards take effect.
HUD Seeks Smoother Transition for HOME Stakeholders
The first delayed provision concerns the limits on how much HOME funding can be invested in each rental unit. The January rule replaced the old static cap with a formula tied to the Section 234 condominium limits, allowing higher per-unit caps in high-cost markets and adding a small bonus for certified green building projects. The intent was to align HOME with modern development costs and help close persistent financing gaps. Because the change is now delayed, local housing agencies must continue using older, lower limits that restrict the amount of HOME support available for projects. This may temporarily limit the scale or feasibility of developments that depend on HOME funds, particularly those layered with LIHTC or bond financing.
The second delayed provision introduces new renter protection and rental addendum requirements. When it takes effect, every HOME assisted rental property will need to include a standardized lease addendum addressing maintenance obligations, notice periods, deposit rules and other renter rights. These changes are intended to promote transparency and consistency but will also increase compliance obligations for owners and managers. The delay gives property operators time to revise lease forms, train staff and coordinate with local housing agencies to ensure smooth adoption.
Balancing Regulatory Readiness with Production Goals
For multifamily developers and housing providers, HUD’s decision prevents sudden disruption in underwriting, legal documentation and project closings while allowing time to prepare for the coming regulatory shifts. However, while the delay in renter protection requirements offers welcome breathing room for owners and managers to adapt, the postponement of the new per-unit subsidy limits prolongs funding constraints that make HOME-assisted development more difficult in today’s high-cost environment. NMHC continues to support HUD’s broader modernization goals but emphasizes that timely implementation of the updated subsidy standards is essential to sustain project feasibility and meet housing production goals.