Towne Tip: HUD Net Family Asset Limit: What Applies and When
HUD's 2016 Streamlining Rule first let Multifamily and PIH programs accept a family's declaration of assets at $5,000 or less, paired with full third-party verification every three years. HOTMA raised that threshold to a figure adjusted annually for inflation, addressed in a different tip in this series. Separately, HOTMA created a new net family assets eligibility restriction, the subject of this piece, a limit that did not exist previously.
The Current Figures
The applicable figure follows the certification's effective date, not the date the file is completed. For a certification effective on or before December 31, 2026, the figure is $105,574. For a certification effective on or after January 1, 2027, the figure is $109,797.
Which HUD Multifamily Programs Net Family Asset Limit Applies To
Section 8 Project-Based Rental Assistance and Section 202/8 are subject to this restriction. Section 202/162 PAC, Section 202/811 PRAC, Section 236 IRP, Section 811 PRA, and SPRAC are HUD Multifamily programs, but this restriction does not apply to them. HUD's methodology notice, 89 FR 27440, states directly that the restriction also does not apply to CDBG, HOME, HOME-ARP, or HTF.
LIHTC is not addressed by this notice. Missouri Housing Development Commission's own manual makes this distinction directly, applying the $50,000 self-certification and imputation threshold to the program while confirming the eligibility restriction itself does not apply. Confirm with your own allocating agency whether its manual addresses this same distinction.
How HUD Calculates the Figure Each Year
HUD derives one national Inflationary Factor from the Consumer Price Index for Urban Wage Earners and Clerical Workers, comparing the average index value for April, May, and June of the current year against the same three months of the prior year. That factor is applied to the prior year's Tracking Amount and rounded to the nearest dollar. HUD publishes the updated figure every August, for use the following calendar year. If the index shows no increase or a decrease, the figure holds at its prior level.
What Happens at Admission
Notice PIH 2023-27/H 2023-10, Attachment A, paragraph A.2, states this directly: "At admission, ownership of net family assets that exceed $100,000 (as adjusted) or ownership of disqualifying real property require denial of assistance. PHAs/MFH Owners do not have the discretion to not enforce or provide limited enforcement of the asset limitation at admission." A.2 also applies this same rule at initial certification for a household that previously lost assistance for late recertification or for paying market rent, once that household needs assistance again.
Example. Certification effective date: December 1, 2026. Household net family assets: $107,000. Applicable figure: $105,574. The household's assets exceed the applicable figure.
Result: the household must be denied.
What happens at the Annual Recertification
Paragraph A.3 gives MFH Owners discretion A.2 does not allow at admission. A property must adopt one of three written policies, documented in the Tenant Selection Plan:
Total non-enforcement. The property does not initiate termination or eviction proceedings for exceeding the threshold.
Full enforcement. The property must initiate proceedings within six months of the reexamination that identified the noncompliance.
Limited enforcement. The household has up to six months to bring assets back under the threshold before proceedings begin.
Initiating a proceeding under full or limited enforcement is not the same as completing it. Paragraph A.5 states that MFH Owners are not required to initiate proceedings immediately, and completing an eviction depends on how the proceeding is resolved, not on the enforcement policy alone.
Example. Certification effective date: March 1, 2027. Household net family assets: $107,000. Applicable figure: $109,797. The household's assets do not exceed the applicable figure.
Result: no enforcement action is triggered.
If that same household's assets were $112,000 instead, exceeding $109,797, the result depends on which of the three A.3 policies the property has adopted, confirmed against the property's own Tenant Selection Plan.
Check Your File Against the Correct Figure
Pull one household file, either a move-in application or an existing resident's reexamination. Identify the certification's effective date, then apply $105,574 if that date is before January 1, 2027, or $109,797 if it is on or after. If this is a move-in application and assets exceed the applicable figure, deny assistance under A.2. If this is a reexamination and assets exceed the applicable figure, confirm which of the three A.3 policies your Tenant Selection Plan has adopted, and apply it.
