New legislation- TARC still needed for NWOHR?

I found an interesting post here on the forum where apparently a hotel address could be used to register for an ARC by obtaining a certificate of domiciliation 住宿證明.

Now, this is a different case because this is the address for ARC, not the address for HHR.

For the address used for HHR, do you think a certificate of domiciliation 住宿證明 from a hotel would also be enough for establishing HHR for the first time?

I guess the actual order of application would be:

  1. Apply for 定居證 at NIA.
  2. After receiving 定居證, apply for HHR at HHR office.

And when applying for 定居證 at NIA, they require a “rental agreement bearing the address”, so the question is if 住宿證明 from a hotel counts as a “rental agreement bearing the address” for the purposes of receiving the 定居證 from the NIA.