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The Office of Housing Finance and Sustainability (OHFS) within the Division of Housing is seeking to increase our communication about Asset Management. We’ll be sending you quarterly updates highlighting changes to inspections, monitoring, and compliance requirements. Subscribe to our DOH OHFS Quarterly Asset Management Update email blasts.
Upcoming Trainings
OHFS Webinar Series
The OHFS Webinar Series is on a quarterly webinar schedule for 2026 and will continue to be recorded and then stored on our training website. This year, we’ll have some presentations from partner agencies. The next webinar will be held on Wednesday, April 29th, from 1pm to 3pm. Balanced Housing Solutions will be presenting “Structuring Housing Preferences Without Violating Fair Housing Laws”. This webinar will cover some of the following topics:
- A refresher on the Fair Housing Act, protected classes, and the ongoing importance of Affirmatively Furthering Fair Housing (AFFH).
- Understanding discriminatory effects (disparate impact) and how to evaluate if a preference could be viewed as creating unlawful segregation or limiting fair housing choice.
- A deep dive into the legal risks and enforcement trends surrounding residency, live/work, veteran, and disability status preferences.
- Best practices for drafting neutral, inclusive language and using evidence-based justifications to minimize legal exposure.
- A review of real-world examples to identify "red flags" and discuss compliant alternatives.
Participants will receive a follow-up resource packet featuring a fair housing preference risk-assessment worksheet and a summary of best practices to help ensure long-term program compliance. We encourage grantees/borrowers, housing authorities, housing developers, compliance staff, and program administrators to attend and ask questions! If you would like to submit questions in advance, please complete this Google Form or reach out to ohfs_webinarseries@state.co.us.
On Wednesday, July 8th, from 10am to 11am, staff from the Colorado Poverty Law Project will present updates on landlord-tenant legislation for 2025-2026.
Both the April 29th and July 8th webinars will be held via Google Meet. The meeting invite link and call-in information for the webinars are listed below:
Video call link: https://meet.google.com/xur-jfip-ypq
Or dial: (US) +1 708-942-5132 PIN: 534 688 628#
More phone numbers: https://tel.meet/xur-jfip-ypq?pin=6165735022998
Previously recorded webinars and the schedule are available on the OHFS Training page. The video meeting information and link are available on the DOH Public Calendar. The OHFS Webinar Series requests your input on future webinar topics. Please complete the OHFS Webinar Series Topic Ideas survey to provide any ideas on topics you would like to see covered. You can subscribe to receive notifications about the OHFS Webinar Series, including reminders for upcoming webinars.
Updates
Tenant Selection Preferences
Per HOME regulation 24 CFR §92.253(d)(3) and HTF regulation 24 CFR §93.303(d)(3), Property Managers are only permitted to give preference to particular segments of a population if it is permitted in the written agreement with DOH and/or described in DOH’s consolidated plan. If a preference was not reported at the time of the project's application or underwriting, it must be approved by DOH before implementation to ensure the preference does not unintentionally discriminate.
During monitoring visits, DOH will inquire about tenant selection preferences. If the property uses a preference not approved by DOH, a formal request for approval must be submitted. This request must address the following questions, but is not limited to:
- Do these preferences apply to all properties that the Property Management company manages?
- Do you find these preferences to be relevant/applicable on an ongoing basis?
- How often does the Property Management company see applicants who are potentially eligible for this preference on its waitlist?
- What analysis has the Property Management company done to ensure no unintentional discrimination takes place when applying preference points to this particular preference?
DOH will follow up with a formal response informing whether the use of the preference has been approved or denied. If the preference is denied, the tenant selection plan and other applicable documents must be updated.
Updated Long-Term Monitoring Risk-Based Monitoring Policy
DOH has updated the Long-Term Monitoring Risk-Based Monitoring Policy to include details regarding when a property is considered “high-risk”. Once a property is considered high-risk and the risk factor cannot be cured with corrective action during the monitoring, that designation will remain in effect until the next monitoring.
It also includes updated procedures for curing the “temporarily out-of-compliance” status after a monitoring has been closed out. DOH allows properties to cure the status in between monitoring cycles in order to regain compliance and avoid an out-of-cycle on-site visit. For further details and submission requirements, DOH encourages reviewing the updated policy, which can be found on the Forms and Guidance page of the website under Policies and Procedures.
Updated Floating DOH Assistance Policy and Training
DOH has updated its policy regarding floating assistance to allow more flexibility for properties to get back into compliance with the unit mix. The following scenarios outline the allowed methods by which a property can float DOH assistance once a household is no longer eligible.
Situation 1: The new unit will be redesignated as HOME or HTF-assisted at the newly designated tenant’s upcoming recertification or at a new move-in.
Situation 2: Assistance can be retroactively redesignated for an existing tenant’s recertification, provided the effective date is within 6 months of the on-site visit. This can only be done if all the following conditions are met:
- The rent amount is within the HOME/HTF limits, and the signed lease reflects an amount within the limits
- Source documents for income and asset verification are already present in the file and are dated before the effective date. The documents must be dated within 6 months of the certification's effective date.
- The tenant’s income is within the HOME/HTF limits.
- The resident and all household members have lawful presence (Federal Funds). A signed residency declaration form will be required.
- Identification is present in the file
- A clarification record explaining this retroactive floating is present in the file
For more information on how to properly float DOH assistance, watch the Floating DOH Assistance training on DOH’s website.
Tracking Transfers from Accessible Units
During long-term monitoring on-site visits, DOH will inquire whether management has transferred any residents in accessible units who did not require those features to a different unit to accommodate an applicant who needed the accessible unit. The number of transfers is reported to HUD’s Office of Fair Housing and Equal Opportunity (FHEO) as part of the Voluntary Compliance Agreement. DOH encourages management to track this information via a database or log. Ensure your property has a transfer policy and is using a transfer lease addendum. Templates of these documents can be found on our Forms and Guidance page under Section 504/Reasonable Accommodation.
As Seen Across the State and Frequently Asked Questions
How do we comply with DOH if our property has already implemented HOTMA?
DOH will expect the tenant file to include full source verification of income and assets, regardless of amount, when full source documentation is required (i.e., move-in/initial eligibility and 6-year source cycle for HOME/HTF units). Six months of checking account statements must still be used to calculate the 6-month average balance. If your software system no longer includes assets on the Tenant Income Certification (TIC) due to HOTMA implementation, DOH will accept either of the following two methods;
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First, you can use a detailed clarification record in the tenant file to cross-reference your HOTMA-compliant calculations with DOH’s current Part 5 requirements. This clarification record should list all income and assets and show calculations of income from assets (if any) included in the gross annual household income amount.
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Alternatively, you can prepare a separate TIC that specifically shows the income and assets calculated in accordance with Part 5 practices for DOH purposes.
When does OHFS intend to roll out the HOTMA updates?
On December 30, 2025, HUD notified its grantees of the compliance date extension to January 1, 2027, for all Community Planning and Development (CPD) programs that use HUD’s 24 CFR Part 5 Income Regulations. DOH has not issued guidance on HOTMA; therefore, partners must continue to follow the Part 5 Income Regulations until further notice.
When does OHFS intend to roll out the NSPIRE (National Standards for the Physical Inspection of Real Estate) updates?
On September 30, 2025, HUD notified its grantees of the compliance date extension for NSPIRE to October 1, 2026. This extension applies to Emergency Solutions Grants (ESG), Continuum of Care (CoC), HOME Investment Partnerships Program (HOME), and Housing Trust Fund (HTF) programs (“CPD programs”). Until further guidance is issued, partner agencies must continue to follow the applicable standard specified in their Grant/Loan Agreement and/or Regulatory Agreement and Use Covenant. DOH will provide further guidance in the coming months.
Do property managers need to observe the Cost of Living Adjustment?
All participants who have an Annual Reexamination, New Admission, or Move with an effective date of January 1, 2026, or later, and who receive Social Security benefits, will need to have the Cost of Living Adjustment (COLA) increase included in their income calculations. The COLA will increase by 2.8% beginning January 2026. For more information, refer to Cost-of-Living Adjustment (COLA) Information for 2026.
What did the HUD passbook rate change to?
Effective January 1, 2026, the HUD passbook rate decreased from 0.45% to 0.40%. DOH expects this new rate to be applied when calculating and comparing total income from all assets exceeding $5,000. DOH recommends that property management and compliance staff check their software systems to ensure this change has been and will be applied to certifications that take effect on January 1 and after.
As Seen Across the State and Frequently Asked Questions
When does OHFS intend to roll out the HOTMA updates?
On December 30, 2025, HUD notified its grantees of the compliance date extension to January 1, 2027, for all Community Planning and Development (CPD) programs that use HUD’s 24 CFR Part 5 Income Regulations. DOH has not issued guidance on HOTMA; therefore, partners must continue to follow the Part 5 Income Regulations until further notice.
When does OHFS intend to roll out the NSPIRE updates?
On September 30, 2025, HUD notified its grantees of the compliance date extension for NSPIRE to October 1, 2026. This extension applies to Emergency Solutions Grants (ESG), Continuum of Care (CoC), HOME Investment Partnerships Program (HOME), and Housing Trust Fund (HTF) programs (“CPD programs”). Until further guidance is issued, partner agencies must continue to follow the applicable standard specified in their Grant/Loan Agreement and/or Regulatory Agreement and Use Covenant. DOH will provide further guidance in the coming months.
Do property managers need to observe the Cost of Living Adjustment?
All participants who have an Annual Reexamination, New Admission, or Move with an effective date of January 1, 2026, or later, and who receive Social Security benefits, will need to have the Cost of Living Adjustment (COLA) increase included in their income calculations. The COLA will increase by 2.8% beginning January 2026.
What did the HUD passbook rate change to?
Effective January 1, 2026, the HUD passbook rate will decrease from 0.45% to 0.40%. DOH expects this new rate to be applied when calculating and comparing total income from all assets exceeding $5,000. DOH recommends property management and compliance staff check their software systems to ensure this change was and will be applied to certifications that take effect on January 1 and after.
Updated Monitoring Forms, Tools, And Policy
The Tenant File Checklist was updated to encompass all DOH funding sources. Documents specifically required for federal funds are referenced in the document. DOH recommends reviewing the checklist to ensure tenant files include all necessary documentation.
The On-site Monitoring Prep Points 2026 document was updated to serve as a resource for on-site monitoring visits. DOH highly recommends reviewing the document before a monitoring visit to have clear expectations and ensure the monitoring process goes as smoothly as possible.
The Summary of CO State Statutes Impacting Landlords and Renters was updated to include legislation passed in 2025. This document is currently being updated to include legislation that took effect in 2026.
2025 HOME Final Rule Summary Memo: DOH has created a memo summarizing the HOME Final Rule published by HUD, which took effect on April 20, 2025. Some provisions, including the tenancy addenda and the increase in the maximum per-unit subsidy limit for projects that meet Green building standards, were delayed until April 30, 2026. DOH recommends that properties with HOME-assisted units, or anyone planning to apply for future HOME funds, read this memo, watch the OHFS Webinar from April 9, 2025, or reach out to their Asset Manager with any questions or for clarification.
In July 2024, DOLA-DOH entered into a Voluntary Compliance Agreement with HUD’s Office of Fair Housing and Equal Opportunity (FHEO). For more information about this voluntary compliance agreement, please check out our January 8, 2025, webinar on the OHFS Training page. As a result of the agreement, DOH is required to supply FHEO with completed compliance certifications for all federally assisted projects. DOH will contact all projects with federal funding that are in their HUD period of affordability to request the executed Accessibility Verification of Compliance form, along with copies of the documents listed on the form. OHFS has created templates for Section 504 policies and various Reasonable Accommodations. They can be found on our Forms and Guidance page. If you have any questions or concerns, please reach out to jennifer.digiallonardo@state.co.us or dola.audit@state.co.us
Questions? Please email us at brittany.thigpen@state.co.us
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