Treasury, HAF Closeout Checklist
Summary
Treasury's self-assessment list for Homeowner Assistance Fund (HAF) recipients considering "early closeout." The award period of performance ends on September 30, 2026, but a recipient may submit its Final Reports before then; once it does, it may not obligate or expend any remaining or returned award funds for any purpose, and it stays subject to records retention and audit requirements. The questions ask whether the budget in Treasury's Portal matches the actual award, whether all payments for mortgage assistance, utility bills and housing counseling have been processed, and whether the ledger and bank accounts are reconciled. Mortgage servicers and utility companies sometimes return HAF funds, so a program still receiving them regularly may wish to delay its Final Reports and redeploy the money to other homeowners.
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“Treasury, HAF Closeout Checklist.”
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HAF Early Closeout Checklist
The Homeowner Assistance Fund (HAF) award period of performance ends on September 30, 2026, but
HAF recipients may opt to engage in “early closeout” by submitting their Final Reports prior to that date.
Use this list to conduct a self-assessment to determine whether you are ready to submit your HAF Final
Reports (“Final Reports”) to Treasury for closeout your HAF Award. This checklist is designed to help
support successful closeout but does not necessarily reflect all the closeout preparation activities in
which a HAF recipient may engage. Recipients that answer “no” to any of the applicable questions
should consider whether they are ready for early closeout of their HAF award.
Remember, once you have submitted the Final Reports to Treasury, you may not obligate or expend
any remaining or returned award funds for any purpose. After your HAF award has been closed out,
you will still remain subject to records retention and audit requirements (see HAF Closeout Resource for
more details).
Does your budget in Treasury’s Portal accurately reflect your actual HAF award budget?
o Note: Recipients may make adjustments to their budgets through Treasury’s Portal, but
these changes should be submitted to Treasury for approval prior to accessing their Final
Reports.
Have you and/or your subrecipient(s) expended all of your HAF award funds? You may no
longer spend HAF award funds once you have submitted your Final Reports to Treasury. It is
critical to ensure that you have completely processed all payments for HAF assistance, services,
and administrative expenses related to implementing your HAF program before you submit your
Final Reports.
o Have you and/or your subrecipient(s) processed all final payments for mortgage
assistance, utility bills, housing counseling, etc.?
Note: Be sure that you do not have any prospective HAF expenses queued for
payment related to mortgage assistance, utility assistance, housing counseling,
operational activities, etc. after submission of your Final Reports to Treasury. A
HAF recipient cannot provide a mortgage servicer, utility company, or
homeowner with HAF funds for prospective assistance if that assistance will
cover a period of time after the submission date of the Final Reports.
o Have you and/or your subrecipients completed all administrative activities and/or
liquidated all HAF award obligations for administrative expenses (staff salaries,
subawards, contracts, etc.)? Administrative activities may include those to support
closeout such as:
Verification that all HAF data submitted in the HAF Final Reports comply with
the requirements set forth in the Homeowner Assistance Fund Guidance, the
HAF Financial Assistance Agreement, and the HAF Reporting Guidance including
that:
◦ Cumulative program and financial data are complete and accurate, as
required by the Quarterly and Annual Reporting requirements.
◦ Information about equipment, supplies, and tangible real property, as
applicable, is prepared in compliance with HAF reporting requirements,
see the HAF Closeout Resource.
Review and reconciliation of general ledger, accounting, reporting, and bank
reconciliation. Review of program policies, procedures, and controls to ensure
eligible use of HAF award funds.
◦ Note: This may involve follow-up with beneficiaries (e.g., homeowners,
servicers, utility companies, etc.) to reconcile documentation, as needed.
These activities can no longer be funded by the HAF award once you
submit the Final Reports.
Preparation for post-closeout activities:
◦ Established staff contact(s) for Treasury to contact during Treasury’s
review of the Final Reports.
◦ Established staff contacts in Treasury’s Portal for any continuing
accounting responsibilities (such as, tracking returned funds, verifying
the Pre-Debt Notice sent by Treasury at the end of Treasury’s review of
your Final Reports for HAF award closeout).
Processes and a resource plan to support ongoing data security measures and
protection of personally identifiable information.
Processes and a resource plan to support the 5-year documentation retention
requirements, in compliance with the HAF Financial Assistance Agreement. See
also the HAF Closeout Resource (page 8)
o If you are not on track to expend your total HAF award, have you contacted Treasury to
discuss your readiness for early closeout?
Are all activities related to your HAF award complete? Before you submit your Final Reports to
Treasury, you should ensure that there are no ongoing activities that were funded by your HAF
award funds. This includes making sure that all activities performed by subrecipients are
complete.
o Are all mortgage assistance, utility assistance, or home repair payments for prospective
services to homeowners complete? Are all home repair activities complete?
Note: HAF award funds can only be used to cover eligible HAF expenses that
occur before the date the HAF recipient submits its Final Reports to Treasury. For
example, propane tanks and fuel purchased to cover utility costs or materials to
support home repair projects must be delivered to and, as applicable, installed
for the homeowners prior to submission of the Final Reports. Additionally, if a
HAF recipient has paid out funds to cover prospective mortgage payments or
utility services, those funds can only cover mortgage or utility services for the
months prior to the date of the submission of the Final Reports.
o Are all the housing counseling and legal services being funded by the HAF recipient’s
award funds complete?
Note: Even if the payment has been made to an organization for providing
housing counseling or legal services, you should not submit the Final Reports
until all activities paid for by the HAF award funds are complete.
Have you considered if your program could receive any returned and/or recovered HAF award
funds that could significantly affect the total HAF award expenditures or obligations?
o Has your program estimated the likelihood of you and/or your subrecipient(s)
continuing to receive returned funds, and if so, would it be possible to redeploy those
funds to other homeowners by keeping your HAF program open?
Note: Sometimes mortgage servicers, utility companies, and other beneficiaries
return HAF award funds. You may wish to delay submitting your Final Reports if
you and/or your subrecipients are still regularly receiving returned funds,
particularly if your program has mechanisms to redeploy those funds to help
homeowners. Any funds returned after the Final Reports have been submitted to
Treasury cannot be redeployed or repurposed and must be returned to Treasury.
o Has your program considered if you and/or your subrecipient(s) expect to recover HAF
funds such as program income or improper payments?
Note: Only recipients with open HAF awards (i.e., not closed out) can redeploy
recovered funds. If you and/or your subrecipients are involved in efforts to
recover funds, you may want to consider delaying submitting your Final Reports
to Treasury until those efforts have settled, particularly if your program has
mechanisms to redeploy those funds to help homeowners. There is one
exception for program income. Recipients that initiate early closeout must return
recovered program income to Treasury between the period that they submit
their Final Reports and September 30, 2026. Recipients are not required to
return program income to Treasury that they received after September 30, 2026
(see page 12 in HAF Closeout Resource).
o Have you created an administrative plan for the post-closeout processing of returned
funds, for instance:
Establishing a process for routing returned payments.
Establishing responsible staff to process returned payments.
Have you resolved any outstanding compliance items that might affect the reporting in your
Final Reports?
o Note: If you are in the process of addressing compliance items, you may wish to
reconsider engaging in early closeout until after those issues are resolved. Once you
submit your Final Reports to Treasury, you will have limited ability to re-obligate or
recharacterize funds. Reconsidering the timing of engaging in early closeout may allow
you more flexibility to respond to compliance items.
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Additional Best Practices
The following questions are additional closeout questions that might help you (1) maintain resources for
homeowners at risk of housing displacement, (2) maintain some of the housing stability infrastructure
developed through the implementation of HAF award funds, and (3) identify and share “lessons
learned” from HAF programmatic efforts.
Have you established any mechanisms to provide ongoing resources to homeowners?
o To the degree it is appropriate within your community, can you provide educational
materials to support homeowner housing stability?
o Have you considered developing referral systems, such as contact information for
housing counseling, housing stability services, legal aid, etc.?
Have you developed mechanisms to maintain housing service networks and community
relations and continue to support homeowner assistance and foreclosure prevention?
Have you analyzed, documented, and disseminated lessons learned from implementation of
your HAF award?
o Have you documented key processes and strategies, as well as recommendations for
future emergency housing programs?
o Have you identified a strategy for maintaining the institutional knowledge developed
through the HAF programs so that future program administrators may benefit from
lessons learned?
o Have you considered developing research partnerships to learn from implementation
efforts of your HAF award?
o Have you contacted Treasury to share lessons learned to inform Treasury maintained
materials about lessons learned?
Note: Treasury has developed an Economic Recovery Learning Agenda which
lists key questions to better understand the impact of your HAF award. If you
would like to share learnings from your research efforts, you can contact
HAF@treasury.gov and/or Treasury’s Office of Strategy Planning and
Performance Improvement: OSPPI@treasury.gov.
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