Treasury, 2025 HAF Compliance Supplement
Summary
The 2025 Compliance Supplement section of the U.S. Department of the Treasury covering the Homeowner Assistance Fund (HAF) program, Assistance Listing 21.026. It states that Section 3206 of the American Rescue Plan Act of 2021, Pub. L. No. 117-2 (March 11, 2021), established HAF and provides $9.961 billion for payments to states, Indian tribes or their tribally designated housing entities and the Department of Hawaiian Home Lands. The supplement sets out program objectives, program procedures and the compliance requirements auditors test, and points to reporting instructions on the HAF program website. It states that at least 60 percent of participants' award funds must be used for mortgage payments, homeowner's insurance, utility payments and other qualified housing expenses for eligible homeowners within a certain target income.
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“Treasury, 2025 HAF Compliance Supplement.”
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Homeowner Assistance Fund Program Treasury
DEPARTMENT OF THE TREASURY
ASSISTANCE LISTING 21.026 HOMEOWNER ASSISTANCE FUND PROGRAM
I. PROGRAM OBJECTIVES
The Homeowner Assistance Fund (HAF) program provides $9.961 billion for the U.S.
Department of the Treasury (“Treasury”) to make payments to states (defined to include the
District of Columbia, Puerto Rico, US Virgin Islands, Guam, Northern Mariana Islands, and
American Samoa), Indian tribes or their tribally designated housing entities, and the Department
of Hawaiian Home Lands (collectively the “eligible entities” or “HAF Participants”) to mitigate
financial hardships associated with the coronavirus pandemic, including for the purpose of
preventing homeowner mortgage delinquencies, defaults, foreclosures, loss of utilities or home
energy services, and displacements of homeowners experiencing financial hardship after January
21, 2020, through qualified expenses related to mortgages and housing.
II. PROGRAM PROCEDURES
A. Overview
Section 3206 of the American Rescue Plan Act of 2021 (the “Act”), Pub. L. No. 117-2
(March 11, 2021), codified as 15 USC 9058d, established the HAF program and provides
$9.961 billion for Treasury to make payments to the eligible entities to provide the
assistance to homeowners for qualified expenses related to mortgages and housing as
described in 15 USC 9058d(c)(1) and Treasury’s HAF Guidance.
Pursuant to 15 USC 9058d(c)(2), at least 60 percent of the HAF participants’ award funds
must be used to provide assistance with mortgage payments, homeowner’s insurance,
utility payments, and other qualified expenses related to mortgages and housing to
eligible homeowners within a certain target income. The law requires HAF participants to
prioritize the remaining award funds to provide assistance to “socially disadvantaged
individuals” (see also the section on “Targeting” in the HAF Guidance).
15 USC 9058d(d) prescribes that the HAF funding must be allocated as follows:
1. $30 million for the US Virgin Islands, Guam, Northern Mariana Islands,
and American Samoa (US territories);
2. $498 million for the Department of Hawaiian Home Lands (DHHL) and
Indian tribes or their tribally designated housing entities; and
3. the remainder for the 50 states, the District of Columbia, and Puerto Rico.
Each state, the District of Columbia, and Puerto Rico will receive a
minimum payment of $50 million. Amounts that will be paid to states, the
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District of Columbia, and Puerto Rico are based on homeowner need as it
relates to unemployment and mortgage delinquencies or mortgage
foreclosures in those jurisdictions.
Amounts paid to US territories are based on share of population, and amounts paid to
tribal entities are based on a formula under 15 USC 9058d(f)(2).
Source of Governing Requirements
Section 3206 of the American Rescue Plan Act of 2021, codified at 15 USC 9058d.
As implemented by Treasury’s HAF guidance available on Treasury.gov, including important
version changes over time that can be found on the site.
Availability of Other Program Information
General information for the HAF program is available through the program website at
https://www.treasury.gov/HAF. Information includes the following documents:
HAF Guidance
Provides guidance on HAF program purpose, definitions, Notice of Request for HAF payments,
qualified expenses, homeowner eligibility, HAF plans, and reporting and monitoring as required
under section 15 USC 9058d.
HAF Reporting Frequently Asked Questions (FAQs)
Provided answers to frequently asked questions on HAF reports.
HAF Quarterly Report User Guide
The User Guide contains detailed guidance and instructions for HAF participants in using
Treasury’s Portal for submitting the HAF Quarterly Report.
HAF Annual Report User Guide
Provides guidance on using Treasury’s Portal to submit the required HAF Annual Report.
HAF Guidance on Participant Compliance and Reporting Responsibilities
Provides detail on HAF participants’ compliance and reporting responsibilities under the HAF
program, and should be read in concert with the HAF Financial Assistance Agreement the HAF
authorizing statute (See pages 60-63), and the HAF Guidance.
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III. COMPLIANCE REQUIREMENTS
In developing the audit procedures to test compliance with the requirements for this federal
program, the auditor must determine, from the following summary (also included in Part 2,
“Matrix of Compliance Requirements”), which of the 12 types of compliance requirements have
been identified as subject to the audit (noted with a “Y” in the summary matrix below), and then
determine which of the compliance requirements that are subject to the audit are likely to have a
direct and material effect on the federal program at the auditee. For each such compliance
requirement subject to the audit, the auditor must use Part 3 (which includes generic details about
each compliance requirement other than Special Tests and Provisions) and this program
supplement (which includes any program-specific requirements) to perform the audit. When a
compliance requirement is shown in the summary below as “N,” it has been identified as not
being subject to the audit. Auditors are not expected to test requirements that have been noted
with an “N.” See the Safe Harbor Status Discussion in Part 1 for additional information.
A B C E F G H I J L M N
Matching, Procurement and
Equipment and
Cash
Period
Activities Allowable
Level of Effort, Suspension and Subrecipient Special
Real Property
Eligibility Reporting
Allowed or Costs/Cost Of Program Tests and
Unallowed Principles Management Management Earmarking Performance Debarment Income Monitoring Provisions
Y Y N Y N Y N N N Y Y N
A. Activities Allowed or Unallowed
HAF participants may use their HAF award funds for qualified expenses related to
mortgages and housing, including for the purpose of preventing homeowner mortgage
delinquencies, homeowner mortgage defaults, homeowner mortgage foreclosures,
homeowner loss of utilities or home energy services, and displacements of homeowners
experiencing financial hardship after January 21, 2020. Please see pages 5 to 8 of the
HAF Guidance for the full list of qualified expenses.
B. Allowable Cost / Cost Principles
HAF funds are considered “other financial assistance” and are administered by Treasury
as direct payments for specified use.
1. Allowable Costs under the HAF program include the following:
a. mortgage payment assistance;
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b. financial assistance to allow a homeowner to reinstate a mortgage or to
pay other housing-related costs related to a period of forbearance,
delinquency, or default;
c. mortgage principal reduction, including with respect to a second mortgage
provided by a nonprofit or government entity;
d. facilitating mortgage interest rate reductions;
e. payment assistance for: (a) homeowner’s utilities, including electric, gas,
home energy, water, and wastewater; (b) homeowner’s internet service,
including broadband internet access service, as defined in 47 CFR 8.1(b)
(or any successor regulation); (c) homeowner’s insurance, flood insurance,
and mortgage insurance; (d) homeowner’s association fees or liens,
condominium association fees, or common charges, and similar costs
payable under a unit occupancy agreement by a resident
member/shareholder in a cooperative housing development; and (e) down
payment assistance loans provided by nonprofit or government entities;
f. payment assistance for delinquent property taxes to prevent homeowner
tax foreclosures;
g. measures to prevent homeowner displacement, such as home repairs to
maintain the habitability of a home or assistance to enable households to
receive clear title to their properties;
h. reimbursement of funds expended by a state, local government, or
applicable tribal entity during the period beginning on January 21, 2020,
and ending on the date that the first funds are disbursed by the HAF
participant under the HAF, for a qualified expense (other than any
qualified expense paid directly or indirectly by another federal funding
source, or any qualified expenses described in clauses (6), (7), (8), or (10)
of this definition);
i. payment of lot rent for a manufactured home, where such payment would
promote housing stability and prevent the default of the resident of the
manufactured home;
j. reimbursement of funds expended by a state, local government, or entity
described in clause (3) or (4) of the definition above of “eligible entity”
during the period beginning on the date the participant received its initial
HAF payment and ending on the date the participant received the balance
of funds requested in the participant’s HAF plan for a qualified expense
consistent with the participant’s approved HAF Plan (other than any
qualified expense paid directly or indirectly by another federal funding
source);
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k. payment assistance or principal reduction for Property Assessed Clean
Energy (PACE) loans, where such expenditures would promote housing
stability and prevent foreclosures or homeowner displacement.
Please see the HAF Guidance on the HAF program page on Treasury.gov for the latest
guidance regarding the eligible uses of HAF funds.
E. Eligibility
1. Eligibility for Individuals
HAF participants were expected to establish and adhere to reasonable policies and
procedures for evaluating homeowners’ applications in accordance with the HAF
Guidance which permits HAF participants to reasonably rely on self-attestation.
Testing of individual homeowner eligibility-related documentation can be limited
to material already collected by the HAF participant in the application as much as
possible to avoid imposing undue burden on homeowners that are experiencing
financial hardships.
The HAF Guidance documents the full eligibility considerations for HAF
participants to extend financial assistance to vulnerable populations without
imposing undue documentation burdens. HAF participants must require all
applications for assistance to include an attestation from the applicant homeowner
that all information included is correct and complete. In addition, HAF
participants are expected to have policies and procedures to determine
homeowner eligibility in the following two criteria:
Financial Hardship: HAF participants may rely on homeowners' attestations that
they experienced financial hardship after January 21, 2020 (including a hardship
that began before January 21, 2020 but continued after that date). The attestation
must describe the nature of the financial hardship (for example, job loss, reduction
in income, or increased costs due to healthcare or the need to care for a family
member).
Income Determination: HAF participants may take one of two approaches to
income verification: (1) the homeowner may provide a written attestation as to
household income together with supporting documentation such as paystubs, W2s
or other wage statements, IRS Form 1099s, tax filings, depository institution
statements demonstrating regular income, or an attestation from an employer; or
(2) the homeowner may provide a written attestation as to household income and
the HAF participant may use a reasonable fact-specific proxy for household
income, such as reliance on data regarding average incomes in the household’s
geographic area. To be eligible for HAF assistance, the homeowner must have
income equal to or less than 150 percent of the area median income (AMI) or 100
percent of the median income for the United States, whichever is greater. When
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determining area median income with respect to Tribal citizens, Tribal
governments and TDHEs may rely on the methodology authorized by HUD for
the Indian Housing Block Grant Program as it pertains to households residing in
an Indian area comprising multiple counties (see HUD Office of Native American
Programs, Program Guidance No. 2021-01, June 22, 2021).
For additional information, please see Treasury’s HAF Guidance at:
https://home.treasury.gov/system/files/136/HAF-Guidance.pdf (See pages 5 - 6).
2. Eligibility of Group of Individuals or Area of Service Delivery
Not Applicable
3. Eligibility for Subrecipients
Not Applicable
G. Matching, Level of Effort, Earmarking
1. Matching
Not Applicable
2. Level of Effort
Not Applicable
3. Earmarking
a. Counseling or educational efforts by housing counseling agencies
approved by HUD, tribal government (including such efforts by in-house
housing counselors who are HUD certified or tribally approved), or legal
services, targeted to households eligible to be served with funding from
the HAF related to foreclosure prevention or displacement, in an aggregate
amount up to 5 percent of the funding from the HAF received by the HAF
participant.
b. Planning, community engagement, needs assessment, and administrative
expenses related to the HAF participant’s disbursement of HAF funds for
qualified expenses, in an aggregate amount not to exceed 15 percent of the
funding from the HAF received by the HAF participant. If the HAF
participant has only received the initial 10% of its allocation, no more than
50% of the initial payment is permitted to be used for the expenses
mentioned here.
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c. Participants are providing not less than 60% of funds to homeowners with
income less than 100% AMI or 100% of U.S. median income.
d. Participants target homeowners that are classified as Socially
Disadvantaged Individuals (SDI) and 100 percent AMI or less.
L. Reporting
1. Financial Reporting
a. SF-270, Request for Advance or Reimbursement – Not Applicable
b. SF-271, Outlay Report and Request for Reimbursement for Construction
Programs – Not Applicable
c. SF-425, Federal Financial Report – Not applicable
d. Other: Quarterly Report (PRA 1505-0269))- Quarterly
Authoritative Requirement: 2 CFR 200.328
Report Instructions:
https://home.treasury.gov/system/files/136/HAF_QuarterlyReportUserGui
de.pdf.
Note: HAF Participants, except for Tribal governments with a HAF award
that is less than $5 Million and the Department of Hawaiian Home Lands,
are required to submit a Quarterly Report each quarter. For Tribal
governments with a HAF award that is less than $5 Million and the
Department of Hawaiian Home Lands, a Quarterly Report is submitted
once-a-year.
Report Corrections: The Office of Recovery Program’s (ORP) reporting
portal has built-in functionality to reopen a report and allow HAF
participants to make edits after the reporting deadline. However, it is
ORP’s policy that HAF participants may only make revisions if authorized
by Treasury staff for a period of up to 60 days after the reporting deadline.
After the revision period ends, the report is final. A resubmitted report
becomes a HAF participant’s final report within ORP’s reporting portal.
HAF participants can generate PDFs of this reports at any time.
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Key Line Items –
1. Administrative Expenses- Quantifiable Objective Criteria:
Obligations and expenditures do not exceed 15% for admin
expenses in the Budget Reporting section, as noted on page 4 of
the HAF Guidance (See item #10).
2. Services, Counseling & Education- Quantifiable Objective
Criteria: Obligations and expenditures do not exceed 5% for legal
services, counseling, and education in the Budget Reporting
section, as noted on page 4 of the HAF Guidance.
2. Performance Reporting
Title of Report: Annual Performance Report
PRA Number: 1505-0269
Reporting Cycle: Annual
Authoritative Requirement:
home.treasury.gov/system/files/136/HAF_AnnualReportUserGuide.pdf
Blank Copy of the Report (see pages 7-20 for screen shots of blank pages of the
report):
https://home.treasury.gov/system/files/136/HAF_AnnualReportUserGuide.pdf
Report Instructions:
https://home.treasury.gov/system/files/136/HAF_AnnualReportUserGuide.pdf
Report Corrections: The Office of Recovery Program’s (ORP) reporting portal
has built-in functionality to reopen a report and allow HAF participants to make
edits after the reporting deadline. However, it is ORP’s policy that recipients may
only make revisions if authorized by Treasury staff for a period of up to 60 days
after the reporting deadline. After the revision period ends, the report is final. A
resubmitted report becomes a HAF participant’s final report within ORP’s
reporting portal. HAF participants can generate PDFs of this reports at any time.
Key Line Item(s)
1. Socially Disadvantaged Individuals- Quantifiable Objective Criteria:
Participants are providing not less than 60% of funds to homeowners with
income less than 100% AMI or 100% of U.S. median income. This key
line item can be found in question 8 of the Programmatic Information
section of the report.
2. Area Median Income- Quantifiable Objective Criteria: Participants target
homeowners that are classified as SDI and 100 percent AMI or less. This
key line item can be found in question 7 of the Programmatic Information
section of the report on page 6 of the HAF Guidance.
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3. Special Reporting
Not Applicable
4. Special Reporting for Federal Funding Accountability and Transparency Act
Although reporting on subaward information is applicable to HAF participants
pursuant to the award term set forth in Appendix A to 2 CFR Part 170, which is
incorporated by reference in the HAF Financial Assistance Agreement, HAF
participants’ compliance with these reporting requirements is not subject to audit.
Compliance Supplement 2025 4-21.026-9
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