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Oregon Housing and Community Services

HOME Final Rule Crosswalk: Summary of Changes for Updated HOME, HTF, and HOME-ARP Compliance

Oregon Housing and Community Services (OHCS) has recently updated its HOME Investment Partnerships Program (HOME), Housing Trust Fund (HTF), and HOME American Rescue Plan (HOME-ARP) Compliance Manual in May 2026.

Below is a summary of updates that were included in the 2025 HOME Final Rule and reflects how these changes were applied in the HOME Compliance Manual.

HOME, HTF, and HOME-ARP development manuals have also be updated.

Property owners and management agents with properties with HOME funding can use the below to understand what has been updated, clarified, or newly implemented. The goal is to help partners understand how these changes may impact ongoing and future HOME compliance practices.

Income Determinations and Verifications

(24 CFR 92.203)

  • Previous: OHCS already adopted the updated methodology in 2025, and the current HOME Compliance Manual incorporates these rules.
  • Updated: Aligns with Housing Opportunity Through Modernization Act of 2016 (HOTMA) and U.S. Department of Housing and Urban Development (HUD) verification hierarchy and income determination. Improves implementation.
  • Implementation: Effective July 1, 2025.

Asset Verification

  • Previous: Third-party asset verification forms required for all move ins.
  • Updated: Aligns with HOTMA. Allows self-certification of assets if under the current asset threshold at move in and recertification.
  • Implementation: Final rule effective April 20, 2025. OHCS HOME Compliance Manual updated to reflect this change.

Rental Assistance Not Included in Gross Tenant Rent (GTR)

  • Previous: Any rental assistance (Housing Choice Voucher (HCV), Project-Based Voucher (PBV), local agency assistance, etc.) must be included in the GTR.
  • Updated: HOME no longer includes federal, state, or local subsidy payments in GTR. New GTR formula: tenant rent + utility allowance (UA). This removes the requirement to include tenant-based rental assistance in the GTR calculation.
  • Implementation: Effective April 20, 2025. OHCS updated the rule in the HOME manual. This change aligns HOME with Low-Income Housing Tax Credit (LIHTC) and Project-Based Section 8 (PBRA).

Subsidy Payment Standard Allowed

  • Previous: HOME units cannot accept voucher payment standards if they exceed maximum HOME rent limits. Gross tenant rent cannot exceed HOME rent limits.
  • Updated: Owners may collect the voucher payment standard of any federal, state, or local rental assistance over the maximum HOME rent limit. Gross tenant rent may exceed the HOME rent limit as long as the tenant receives at least $1 in rental assistance.

    The revised HOME rule states “any federal, state, or local government renal assistance program. Applies to HCV, PBV, PBRA, payments. No longer limited to be only project based.
  • Implementation: Effective April 20, 2025. Aligns with LIHTC and HUD.

Over-Income Tenants in LIHTC/HOME Units

  • Previous: Older language is not clear on owners charging over-income households more than LIHTC maximum rent when adjusting rents for these households.
  • Updated: Updated clarification that over-income household rents may not exceed LIHTC maximum rent if household income goes above HOME 80% income limit.
  • Implementation: Regulation unchanged; only clarifying language added. This rule only applies to HOME units layered with LIHTC and allows a participating jurisdiction (PJ) not to require partners to calculate adjusted income for determining rent as optional.

Rent Compliance in Low-HOME Units with LIHTC

  • Previous: Owners must use the most restrictive rent between LIHTC and HOME program maximums.
  • Updated: A Low-HOME/LIHTC unit is considered Low-HOME if the gross rent complies with the LIHTC Rent Restriction (24 CFR 92.252(a)(2)(iii)).
  • Implementation: New HOME commitments: not eligible at move-in; annual recertification only at 60% AMI or greater. Existing HOME properties: not eligible at move-in; subject to regulatory document review required and only at annual recertification with household income at 60% AMI or greater

Safe Harbor Income Determinations

  • Previous: The manual allowed property owners/agents to accept documentation from the rental assistance agencies but does not state this for public assistance agencies. It does not allow for this acceptance of move-ins, only recertifications.
  • Updated: Updates language from “PJ must require” to “Owner/agent may accept” documentation from rental and public assistance agencies for determining household income.
  • Implementation: Updated in HOME Manual May 2026.

New Tenant Protections and Selection

  • Previous: Using current protections listed on the HOME Lease Compliance form.
  • Updated: HUD delayed implementation indefinitely (announced April 29, 2026).
  • Implementation: No changes to current protections.