Compliance Briefing — October 22, 2025

Executive briefing: HUD pushed the effective dates for the HOME Investment Partnerships Program updates in 24 CFR 92.250 and 92.253 to April 30, 2026, giving participating jurisdictions six more months to align underwriting, subsidy-layering, and lease provisions with the 2025 final rule.¹ The agency reiterated that previous delays from February and April 2025 remain in place, and this notice simply extends the compliance clock again.¹

Key compliance checkpoints

• Policy refresh. Update HOME underwriting, subsidy, and tenant-lease policies to reflect the April 30, 2026 implementation date while preserving drafting momentum.¹
• Project pipeline review. Reassess 2025–2026 commitments to determine which projects will close before the new effective date versus those that must satisfy the revised requirements.¹
• Stakeholder briefings. Notify subrecipients, developers, and property managers about the extension so contract amendments and training schedules align with the updated compliance horizon.¹

Operational priorities

• Documentation control. Version control policy manuals, checklists, and template agreements that were staged for October 30 activation so they are ready for April implementation.
• Training cadence. Reschedule staff and partner trainings to occur closer to the 2026 effective date while maintaining interim refreshers on underwriting and leasing changes.
• Monitoring alignment. Adjust internal monitoring plans and on-site review scopes to capture compliance with current rules through April 2026 and to test readiness for the new provisions.

Enablement moves

• Coordinate with finance and legal teams to map how the extended timeline affects written agreements, affordability monitoring, and subsidy layering documentation.
• Use the delay to pilot compliance checklists on a subset of projects, validating that data systems capture the revised lease and underwriting fields.

Sources

• HUD final rule extending HOME 24 CFR 92.250 and 92.253 effective dates to April 30, 2026

Zeph Tech tracks HUD HOME updates, surfaces date shifts, and supports housing teams with implementation checklists.

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