Policy Alert: Guidance Released for Homeowner Assistance Fund

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Policy Alert: Guidance Released for Homeowner Assistance Fund

April 14, 2021

On Wednesday, April 14, 2021, The U.S. Department of the Treasury released guidance regarding the Homeowner Assistance Fund (“HAF”). The HAF allocates nearly $10 billion to assist homeowners experiencing financial hardship after January 21, 2020 and is part of the American Rescue Plan Act of 2021


The HAF sets aside $498 million specifically for Tribes, Tribally designated housing entities, and the Department of Hawaiian Home Lands. Funds from the HAF may be used for assistance with mortgage payments, homeowner’s insurance, utility payments, internet service, delinquent property taxes, and other specified purposes.  


Summary of Guidance


Notice of Funds Request

In order to access these funds, tribal governments and entities must submit a request to receive payment from the HAF, otherwise known as a notice of funds request. The deadline for Tribes or tribal entities to submit a notice of funds request is September 30, 2021.


Financial Assistance Agreement

Once approved to receive payment from the HAF, Tribes or tribal entities must enter into a financial assistance agreement with USDT before funds will be disbursed. A template for such an agreement can be found here.


Initial Payments

After a financial assistance agreement is entered into with USDT, an initial payment of 10% of the total amount allocated will be made to the Tribe or tribal entity. This payment comes with some restrictions on its usage but USDT encourages participants to create or fund pilot programs to directly serve targeted populations with these funds.


HAF Plans

To receive HAF funds beyond the 10% initial payment, Tribes or tribal entities must develop and submit a plan for its use of HAF funding. A template for the HAF Plan is forthcoming but it is expected to include the following elements: Homeowner Needs and Engagement, Program Design, Performance Goals, Readiness, and a Budget. Treasury will assess HAF plans based on the following factors: Alignment of Community Needs and Program Design, Alignment of Performance Goals with Data on Targeted Populations, Methods of Targeting, Readiness, Alignment of Budget with Performance Goals. 

Treasury is aware that Tribal populations consist largely or entirely of socially disadvantaged individuals and Tribal HAF plans can be tailored to reflect the limited effort necessary to target its programs for those individuals.


Currently, eligible entities must submit a completed HAF plan or a date by which a HAF plan will be submitted by June 30, 2021. It seems likely that this date was chosen with the much earlier April 25, 2021 notice of funds request deadline applicable to States and Territories, in mind. We will reach out to Treasury for clarification regarding the application of this deadline to Tribes and tribal entities.

 

Reporting and Monitoring

HAF participants will be required to submit quarterly reports to Treasury that include financial data, targeting data, and other information. Treasury will release additional guidance regarding HAF reporting. HAF participants will also be required to submit an annual program report to Treasury regarding the impact of the HAF program.


NAFOA encourages tribal leaders to submit notice of funds requests for HAF funds in order to provide critical funding for tribal homeowners experiencing financial hardship. We will continue to share updates and guidance as we receive it.


For any other questions or concerns, please contact Will Stringer, Policy Specialist, at will@nafoa.org.



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