Medium-form · ~1,400 words · Authored by the Regtime Marketer team
Lease-up under HPD and HDC rules is not a standard leasing exercise. It is a regulated marketing process running six to twelve months from plan submission to substantial occupancy, with compliance gates at every stage. Developers new to the process frequently underestimate the timeline and overestimate what a market-rate leasing team can absorb. This primer walks through what actually happens, start to finish.
Start with the Marketing Plan
Every affordable housing lease-up begins with a Marketing Plan submitted to HPD through Housing Connect. The Notice of Intent and Marketing Agent Approval Request typically goes in approximately seven months before anticipated occupancy, or around 70% construction completion for projects using a Certificate of Occupancy target. The plan contents include:
- Unit registration (unit-by-unit list of affordable unit designations).
- Rents, income ranges, and set-asides or preferences.
- Amenities and fees.
- Applicant selection and rejection criteria.
- Language Access Plan.
- Management Plan governing ongoing operations and compliance.
HPD approves the plan. Approval is a gate — no advertising can run until it clears.
Advertising requirements
Advertising is more prescriptive than most sponsors expect. The standard marketing window for projects of 20 or more units is at least 60 calendar days. Modified Marketing windows can be shorter, but no less than 21 days. Homeownership projects run 30 days for 1–6 units or 60 days for 7 or more.
Print advertising is still required under Standard Marketing. Ads must run in at least three newspapers:
- A citywide daily.
- An ethnic-based publication.
- A local publication.
Each ad must run at least three days, including at least one weekend day. Language access requirements mean non-English ethnic papers must carry ads in that language, and appointments must offer free interpretation — including American Sign Language — with applications translated into each applicant’s preferred language.
The lottery
All applications — whether submitted online via Housing Connect or on paper — are randomized together after the advertising window closes. Paper applications are picked up seven to ten business days after the deadline and entered into the lottery. Each application is assigned a unique log number.
The processing order runs through a defined sequence:
- Disability set-aside units: 5% for mobility disability; 2% for vision or hearing disability.
- Community Board preference: 20% of units (reduced from 50% under the 2024 Noel settlement).
- Municipal Employee and Military Veteran preference: 10% combined (effective November 15, 2025).
- Other approved preferences.
- NYC residents before non-residents within the general pool.
Within each tier, applications are processed in log-number order. Applicants have five weekdays to respond to notifications.
Apparently Income Eligible (AIE) review
When an applicant’s log number is reached, Housing Connect takes a “snapshot” of the applicant’s data — this locks the household composition, income, and assets declared at application time. The marketing agent evaluates this snapshot and generates an AIE notification in the applicant’s preferred language if the applicant appears to qualify.
Applicants have at least 10 weekdays to respond with documents. Post-snapshot changes — new employment, a household member’s departure, changed assets — generally cause rejection, unless the applicant documents Extenuating Circumstances.
Document verification
As of April 2025, HPD’s Marketing Handbook reflects HOTMA-aligned document requirements:
- Employment income: one month of paystubs (four if weekly, two if biweekly or semi-monthly). Tax returns are no longer required for employed applicants.
- Self-employment: most recent tax return plus a CPA projection or self-certification.
- Assets: self-certification if under HUD thresholds. Bank statements are not required if assets are under $50,000.
- Voucher holders: credit checks are not permitted, per the September 2023 policy codified in April 2025.
A second document request adds another five weekdays. Rejection triggers a five-business-day appeal window with supervisor review.
Tour and final approval
Eligibility appointments must be accessible, private, conducted within NYC, and available evenings and weekends. At the appointment, the applicant signs a Tenant Income Certification, Asset Certification, Pre-lease Acknowledgment, and Primary Residence Affidavit. The marketing agent then submits the file to the agency (HPD or HDC) for sign-off.
No move-in or lease-signing can occur until the agency approves the file. Starting in April 2025, HPD codified an audit-based review process: a random sample of files undergoes full review, and LIHTC units receive full file review regardless of sampling.
Post-lease-up
After substantial occupancy, the marketing agent submits a closeout package:
- Initial move-in certification (the “W” form).
- Final rent roll.
- Final lottery log.
- Statistical report on applicant demographics and disposition.
The agent transitions the building to ongoing compliance — waitlist management, re-rentals, annual recertifications, and the DHCR registration workflow.
Who can run lease-up
Since September 12, 2022, marketing agents have been required to be on HPD and HDC’s Pre-Qualified List. The PQL contained roughly 63 firms as of April 2025. Per-project approval is still required even for PQL-listed agents. An agent’s duties include:
- Outreach, advertising, and paper application intake.
- Lottery batch generation through Housing Connect.
- Eligibility verification and appeals.
- Secure file storage for at least six years.
- Lease execution and move-in certifications.
- Rent roll submissions.
- Ongoing compliance through the benefit period.
Timeline reality
From marketing plan submission to substantial lease-up, plan on eight to twelve months. Marketing should begin four to seven months before construction completion. Starting later compresses the schedule and almost always produces occupancy gaps.
Re-rentals — the July 2025 addendum
From May 1, 2025 through April 30, 2026, HPD and HDC suspended the Housing Connect Mini-Lottery requirement for re-rentals in a temporary addendum. HPD-regulated projects publicize vacancies on a commercial platform plus the HPD website. HDC projects post to the HDC website with HDC approval. The approach is first-come, first-served or a written waitlist or transfer procedure, with no preferential notification based on current or former residence. Agency approval runs on a three-business-day FormAssembly webform. Pre-move-in approval is still required for HDC, 421-a, 485-x, 467-m, and IH projects.
What this means for developers
Affordable housing lease-up is a managed, audited process with its own pacing. The most common mistakes sponsors make are (a) starting the marketing workstream too late, (b) treating advertising language-access requirements as optional, and (c) underestimating how long agency file review takes after appointments. None of these are unsolvable — they just require the lease-up team to be on the critical path from the moment the Notice of Intent is filed.
Regtime Marketer is HPD-approved and manages affordable lease-up end-to-end — plan submission, advertising, lottery execution, eligibility review, agency file submission, and closeout. Housing Line, our affiliated HPD-approved Administering Agent, handles Inclusionary Housing projects.
