Under federal housing rules, what assets count for Section 8 depends on the asset: bank accounts and stocks can count, but IRAs and 401(k)s are excluded from net family assets., The Department of Housing and Urban Development (HUD) counts assets for Section 8 and public housing under its rules implementing the Housing Opportunity Through Modernization Act (HOTMA). Money your parent gave away for less than it was worth in the two years before applying can still count toward her HUD net family assets for Section 8 and public housing. If you're helping Mom apply to a HUD senior building, it's natural to worry that her savings, her IRA, or last year's gift to a grandchild could cost her the apartment. Below, each common asset gets a plain answer, along with what it changes: whether she qualifies, what she pays in rent, or nothing at all.

In This Guide

Why the Answer Depends on HOTMA

Some of what you'll find online about Section 8 assets was written before the Housing Opportunity Through Modernization Act of 2016 (HOTMA) rules took effect, so it's easy to come away more frightened, or more relaxed, than you should be. The U.S. Department of Housing and Urban Development (HUD) now measures a family's "net family assets," and under 24 CFR 5.618, public housing and Section 8 assistance may not be given, at admission or at a later income review, to a family whose net assets exceed $100,000, a figure HUD adjusts each year for inflation. HUD's published inflation table puts the net-family-asset limit at $105,574 for 2026 and $109,797 for 2027.

There's one timing wrinkle every family should know about. HUD says an agency or property that isn't yet complying with HOTMA sections 102 and 104 doesn't use the inflation-adjusted table. For public housing agencies, HUD's Office of Public and Indian Housing (PIH) said in Notice PIH 2026-15 that it will enforce compliance with HOTMA sections 102 and 104 starting January 1, 2027, except for Moving to Work agencies and agencies using only HUD's Family Reporting Software, whose date HUD will announce later. If Mom is applying to a privately owned HUD building, ask the building manager directly which rules the property is using today. Because the figures in this guide are HOTMA figures, asking which rules the property uses tells you whether they apply to her yet.

What Counts and What Doesn't, Asset by Asset

Most families arrive with a short list: a checking account, some savings, maybe an IRA, and a lot of worry about the one thing they're not sure of. This table answers the common items first. Each row is explained in more detail further down.

Asset Counts toward net family assets? What else to know
Checking and savings accounts Only if all of her non-necessary personal property together is worth more than $52,787 (2026); then the whole total counts Interest the account actually earns still counts as income
Stocks and bonds Same rule as bank accounts Actual dividends or interest still count as income
IRA, 401(k) or other IRS-recognized retirement account No Periodic payments out of the account count as income when received
Necessary personal property No Items needed to live in the home, or for work, school, or health and wellness
ABLE, 529 or Coverdell education account No Also excluded: "baby bond" accounts and Family Self-Sufficiency accounts
Irrevocable trust no family member controls No, while it stays that way Ask the housing office how payments out of the trust are treated
Federal tax refund or refundable tax credit No, for 12 months after she receives it The exclusion runs 12 months from the date she receives it
The home she owns Handled under a separate HUD rule See the home section below

The table draws on HUD's net-family-asset definition in 24 CFR 5.603 and HUD's HOTMA guidance for housing agencies and owners.,, Under 24 CFR 5.603, ABLE accounts, 529 qualified tuition programs, Coverdell education savings accounts and government-funded "baby bond" accounts are all excluded from net family assets, as are federal tax refunds and refundable tax credits for 12 months after the family receives them.

Some items aren't in the table on purpose. We haven't confirmed how HUD treats a burial plan, a prepaid funeral contract or cash-value life insurance, so this guide doesn't give an answer for them. If Mom owns one of these, ask the housing agency or building manager how they'll count it, and get the answer in writing if you can.

Which Buildings Have the Section 8 Asset Limit?

The net-asset limit doesn't apply the same way in every building that calls itself senior housing, and that's often the first thing to sort out. HUD's 2026 table lists the $105,574 net-asset limit for Section 8 project-based rental assistance, Section 202/8, Housing Choice Vouchers, public housing, Section 8 Moderate Rehabilitation and Housing Opportunities for Persons With AIDS (HOPWA). HUD's table does not list the net-asset limit for Section 202 or Section 811 PRAC buildings, and the regulation itself says it applies to the Section 8 and public housing programs.

So which kind of Section 202 building is Mom looking at? HUD's occupancy handbook treats Section 202/8, Section 202 PAC, Section 202 PRAC and Section 202 without assistance as separate program types. Older Section 202/8 buildings were financed with HUD loans and built with Section 8 assistance; that loan program stopped making loans in 1991, although many of those buildings are still in service. Since October 1991, HUD has funded Section 202 housing with interest-free capital advances paired with Project Rental Assistance Contracts (PRACs). The building manager can tell you which contract the building has.

Please don't read "not listed" as "assets don't matter." HUD lists Section 202/811 PRAC among the programs that use its imputed asset income threshold, so savings can still affect what Mom pays in a PRAC building. The rent section below explains how.

How Much Money Can Mom Have in the Bank?

This is usually the question behind all the others, and the answer has two parts. Under HUD's HOTMA guidance, bank accounts, savings accounts, stocks and bonds are "non-necessary personal property," a category HUD defines as anything that doesn't qualify as necessary personal property. Necessary personal property, in HUD's notice, means items the family needs for the maintenance, use and occupancy of its home, or needs for employment, education, or health and wellness; it does not include bank accounts, other financial investments or luxury items.

Here's the first part. Under 24 CFR 5.603, when the combined value of all of a family's non-necessary personal property is no more than $50,000, adjusted for inflation, none of it counts toward net family assets. HUD's inflation-adjusted threshold for non-necessary personal property is $52,787 for 2026 and $54,898 for 2027. When non-necessary personal property is worth more than HUD's threshold ($52,787 in 2026), its total value is included in net family assets, not just the amount over the threshold. For example, if Mom's only non-necessary property in 2026 were $40,000 in savings and stocks, it would add nothing to her net family assets; if it were $60,000, the full $60,000 would count, which is still under the $105,574 limit.,

The second part is easy to miss. HUD's HOTMA notice says annual income includes all actual anticipated income from assets, even when the asset itself is excluded from net family assets, unless that income is excluded for some other reason. So the interest on a small savings account still gets reported as income, even when the account doesn't count as an asset. It's usually a small number, but it belongs on the application.

Does an IRA or 401(k) Count for Section 8?

Under HOTMA, no: the value of any account in an IRS-recognized retirement plan, including IRAs, employer plans such as a 401(k), and plans for self-employed people, is excluded from net family assets under 24 CFR 5.603. HUD's HOTMA notice adds that money earned on the funds while they sit in the account isn't treated as income from assets either. If Mom has spent years worrying that her IRA would disqualify her, that worry can come off the list.

What does count is money coming out. Under 24 CFR 5.609, any distribution of periodic payments from a retirement account counts as income at the time the family receives it. HUD's own example in its HOTMA notice is a family receiving $1,000 a month from a 401(k): the income review leaves out the 401(k)'s value and earnings, but it includes the $12,000 in distributions as unearned income.

A one-time withdrawal is a different situation, so slow down before Mom takes one. HUD's rule speaks to periodic payments, so ask the housing agency or building manager how a single withdrawal would be treated before she makes it. And once money leaves the retirement account and sits in her checking or savings account, that account is non-necessary personal property like any other. For broader planning around those accounts, our guide to retirement accounts and paying for care can help.

Gifts, Trusts and the Two-Year Rule

Many families find this part the hardest, because the gift was made out of love, often long before anyone was thinking about housing. Under 24 CFR 5.603, net family assets include the value of assets a family disposed of for less than fair market value in the two years before the application or income review, to the extent the value exceeded what the family received for them. HUD's two-year rule covers a disposition in trust, but not a foreclosure or bankruptcy sale. A transfer made as part of a separation or divorce settlement is not treated as below fair market value if the applicant or tenant receives something in return that can't be measured in dollars.

Trusts work in two directions. Under 24 CFR 5.603, a trust that no member of the family or household can revoke or control isn't a family asset, and its value stays out of net family assets for as long as it's held that way. HUD's HOTMA notice explains that a "disposition in trust" means the family creating a trust for someone outside the assisted family, which falls under the two-year rule; setting up a nonrevocable trust for someone inside the assisted family is not treated as a disposal below fair market value. If payments come out of a trust to Mom, ask the housing office how it will treat them.

HUD's two-year rule is not the same as Medicaid's look-back. Medicaid applies a 60-month look-back to uncompensated transfers when it decides eligibility for long-term care, and a transfer inside that window can trigger a penalty period during which Medicaid won't pay for that care. HUD instead counts the given-away value in the family's net assets, and its window is two years rather than Medicaid's 60 months., If nursing home care could be ahead, a gift that seems harmless for housing can still matter for Medicaid, and our guide to the Medicaid look-back period walks through that rule.

How Savings Can Change the Rent

Even when Mom is well under the limit, her assets can still nudge her rent, and it helps to know why before the first rent notice arrives. Under 24 CFR 5.609, when a family's net assets are above $50,000, adjusted for inflation, and the actual return on an asset can't be calculated, the family's annual income includes an imputed return on that asset at HUD's passbook savings rate. HUD's imputed asset income threshold is $52,787 for 2026 and $54,898 for 2027, and HUD's passbook savings rate is 0.40% for 2026 and 0.38% for 2027. When net family assets are at or below HUD's imputed asset income threshold ($52,787 in 2026), no imputed return is counted for an asset whose actual income can't be determined. HUD lists the imputed asset income threshold and passbook rate for public housing, Housing Choice Vouchers, Section 8 project-based buildings, Section 202/8 and Section 202/811 PRAC buildings.

Why does added income matter? In public housing and Section 8, the family's rent contribution, called the total tenant payment, is the highest of several amounts, starting with 30 percent of the family's monthly adjusted income. More counted income, whether actual interest, retirement distributions or an imputed return, can raise that 30 percent figure. Our guide to how HUD calculates senior rent walks through the deductions that come off first.

What If Mom Owns a Home?

Owning a home is handled under a separate HUD rule, apart from the personal-property threshold, so the $52,787 personal-property threshold doesn't settle it. Under 24 CFR 5.618, public housing and Section 8 assistance may not be given to a family that has a present ownership interest in, a legal right to reside in, and the effective legal authority to sell real property suitable for the family to live in. HUD's home rule doesn't apply to a family that is offering the property for sale, among other exceptions. A property also isn't "suitable for occupancy" if the family shows, for example, that it doesn't meet a family member's disability-related needs, isn't safe to live in, or is located in a way that creates a hardship. Separately, 24 CFR 5.603 excludes the value of real property the family doesn't have the effective legal authority to sell.

If Mom is already a tenant, the timing and the agency's own policy matter. When recertifying a current family, a housing agency or owner may choose not to enforce the asset and home restrictions, or may set exceptions based on factors such as age or disability, but only under a policy it has adopted. If she has already missed a recertification, see what to do after a missed HUD recertification. For most public housing agencies, HUD's enforcement of HOTMA sections 102 and 104, which include the asset limit and home-ownership restriction, starts January 1, 2027; Moving to Work agencies and agencies using only HUD's Family Reporting Software will get a later date. Our affordable senior housing guide covers the home rule alongside the other ways older adults qualify.

Your Next Steps

None of this has to be settled in one sitting. These steps, in roughly this order, tend to save families the most worry:

  1. Ask the housing agency or building manager two questions: is the property following HOTMA rules yet, and is it public housing, a voucher, Section 8 project-based, Section 202/8 or Section 202 PRAC?
  2. List Mom's assets by type, using the table above, and add up her bank accounts, stocks and bonds to see where she falls against HUD's $52,787 non-necessary personal property threshold for 2026.
  3. Write down any gifts, or sales below what something was worth, from the last two years, with dates and amounts. The agency will ask, and it's easier to answer from notes.
  4. Before Mom takes a one-time retirement withdrawal, moves money into a trust, or gives anything away, ask the housing office how it will be treated, and talk with a qualified professional if Medicaid may be in her future.
  5. Keep copies of every statement you hand over, and ask for any answer that worries you in writing.

Frequently Asked Questions

Can Mom give me her savings before she applies?

She can, but a gift made in the two years before Mom applies still counts in her HUD net family assets, to the extent it exceeds what she got back, so it won't help her qualify for Section 8 or public housing. The two-year rule section above shows how the amount is figured and how it differs from Medicaid's look-back, so talk with the housing office, and a qualified professional, before moving money to fit under a limit.

Mom is already a tenant and her savings grew. Could she lose her apartment?

Not automatically. A housing agency or owner may delay starting eviction or termination for up to 6 months for a family out of compliance with HUD's asset limit or home-ownership restriction, unless that conflicts with other law. The agency or owner may also have adopted a policy not to enforce those restrictions at recertification, as the home section above explains, so ask for its written policy before assuming the worst.

Does Section 202 PRAC senior housing count Mom's assets?

Yes, in the rent calculation: HUD applies its imputed asset income rule, with a $52,787 threshold for 2026, to Section 202 and Section 811 Project Rental Assistance Contract (PRAC) buildings. Under HUD's PRAC regulation, an applicant must be a very low-income family, and a household stays eligible for the rental subsidy until its total tenant payment equals or exceeds the gross rent. So counted income from savings can raise what Mom pays in a PRAC building, but the subsidy itself continues until her payment reaches the gross rent.

Will the housing office ask for every bank statement?

Not always. HUD lets a housing agency or owner accept a family's own certification that its net family assets are no more than $52,787 in 2026 ($54,898 in 2027), without further verification. The family's declaration must state the income it expects from those assets, and that amount is counted as income. Whether to accept a certification is the agency's or owner's choice, so be ready with statements anyway.

Learn More

Care TypesAffordable Senior HousingSection 202, public housing and Section 8 vouchers cut rent for low-income older adults. See who qualifies, what rent costs and how to get on a waiting list. Care TypesHow HUD Calculates Senior RentSeniors' medical costs above 10% of income, plus a $550 elderly family deduction for 2026, come off income before HUD sets rent under HOTMA. Here's the math. Care TypesUsing a Section 8 Voucher in Assisted LivingYes, if your housing agency allows it, but a Section 8 voucher pays only the rent, never the care. What Medicaid covers, what you'll owe and the steps. Care TypesKeeping Subsidized Housing During a Nursing Home StayNot right away. With a Section 8 voucher, Mom can be away up to the housing agency's limit, never over 180 days. A Section 202 building follows house rules. MedicaidThe Medicaid Look-Back Period ExplainedThe Medicaid look-back period reaches 60 months back from your application. Here's how a gift delays nursing home coverage, the exemptions, and state rules. VA BenefitsVA Net Worth and the Look-BackHow the VA pension net worth limit ($163,699) and the 3-year look-back work in 2026, including penalty period math and how to avoid transfer mistakes.

Chat with Brevy's care navigator about which of Mom's assets count for her HUD housing application at brevy.com.

The information on Brevy.com is for educational purposes only and is not a substitute for professional legal, financial, or medical advice. Rules vary by state and program and change frequently. Always verify with the relevant agency or a qualified professional. Brevy is not a law firm, financial advisor, or healthcare provider.

Still have questions?

Brevy answers from this guide and every other guide here, and can check what you qualify for.

BC

Brevy Care Team

Expert eldercare guidance from Brevy's team of healthcare professionals and researchers.