Treasury, HAF Closeout Resource
Summary
Treasury's closeout resource for Homeowner Assistance Fund (HAF) recipients. The period of performance, including Tribal allocation adjustment payments, ends on September 30, 2026, the last day recipients may obligate HAF award funds for administrative and program expenses. Those obligations must be paid in full within 120 calendar days, during the liquidation period (October 1, 2026 - January 28, 2027), and included in the Final Reports, which must be submitted to Treasury by January 28, 2027. Closeout is meant to confirm that funds were expended on allowable costs, that unobligated and unexpended balances are returned to Treasury, that real or tangible personal property bought with HAF funds is accounted for, and that recipients certify their Final Reports comply with the HAF Financial Assistance Agreement. A second section lists post-closeout compliance reminders.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Cite this document
“Treasury, HAF Closeout Resource.”
Original at home.treasury.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/treasury-haf-closeout-resource-d159e0239b/
, SHA-256 4e31eb125c4a10762e465d591dc2750651d658d50f55737a60349d84068a78d2.Full text
U.S. Department of the Treasury
Homeowner Assistance Fund (HAF): Closeout Resource
The following information is to be used as a resource by HAF recipients (“recipients”) 1 for
closeout of their Homeowner Assistance Fund (HAF) awards. The period of performance for
HAF awards (including Tribal allocation adjustment payments, as applicable) ends on September
30, 2026.
• Section I of this document details closeout information and resources.
• Section II of this document provides additional post-closeout compliance reminders.
Recipients are advised to monitor the HAF Guidance page on Treasury’s website for additional
compliance resources.
Section I: Closeout Information and Resources
General Closeout Overview
The purpose of award closeout is to ensure that:
• recipients have completed the HAF award objectives as outlined in their HAF plan.
• HAF Final Reports indicate that HAF award funds were expended on allowable costs.
• any balances of unobligated and unexpended funds remaining on the HAF award are
returned to Treasury.
• a proper accounting of any real or tangible personal property purchased with HAF award
funds is submitted.
• recipients certify that the data submitted in the HAF Final Reports comply with the terms
and conditions of the HAF Financial Assistance Agreement (HAF FAA). 2
The period of performance (POP) for HAF awards ends on September 30, 2026 (end of the
award term), which marks the last day that recipients may obligate HAF award funds for
administrative and program expenses, and such obligations must be paid in full within 120
calendar days after September 30, 2026 to facilitate inclusion of those transactions in the Final
Reports.
For the purposes of this document, please note the following distinctions:
1
HAF Guidance also refers to HAF recipients as “HAF Participants.” These terms may be used interchangeably.
2
Note the HAF FAA stipulates federal regulations applicable to this award include Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), 2 C.F.R. Part 200,
other than such provisions as Treasury may determine are inapplicable to this award and subject to such exceptions
as may be otherwise provided by Treasury. HAF recipients continue to be subject to the November 12, 2020 version
of 2 C.F.R. Part 200 in effect at the time that the HAF FAA were executed by HAF recipients, unless otherwise
specified. See eCFR :: 2 CFR Part 200 (Nov. 12, 2020) -- Uniform Administrative Requirements, Cost Principles,
and Audit Requirements for Federal Awards.
HAF Program Closeout Resource
• recipients that have not initiated award closeout and the award POP has not expired will
be referred to as having “open awards.”
• recipients that submitted the Final Reports to Treasury for closeout of their HAF award
within 120 calendar days after September 30, 2026 are in “standard closeout.”
• recipients may choose to initiate the award closeout process before September 30, 2026
and those that do so are engaged in “early closeout.”
• “closed awards” refer to recipients for which Treasury has completed its closeout
process on their award and issued a Notification of Completion to the recipients.
All recipients are required to submit their Final Reports to Treasury to close out their HAF
award. The “Final Reports” consist of two reports, the HAF Annual Report and the HAF
Quarterly Report, which includes a special section for tangible personal property. 3 Treasury
reserves the right to request additional documents to support the Final Reports. Failure to
submit timely and accurate Final Reports may result in administrative closeout and affect
future Federal funding to the HAF recipient. 4 Treasury may also pursue other enforcement
actions per 2 CFR 200.339. No later than 120 calendar days after September 30, 2026, recipients
must complete the following closeout activities:
• reconcile financial expenditures associated with the HAF award.
• liquidate all HAF award obligations incurred by September 30, 2026.
• determine whether any balances of unobligated and unexpended funds remain on the
HAF award.
• determine the status of all real and tangible personal property and unused supplies
purchased with HAF award funds.
• prepare and submit the required Final Reports to Treasury.
Figure 1: General Closeout Process
•
Recipient Recipient
•
conducts award Recipient returns Treasury
Treasury
closeout submits Final unspent or sends
Closeout
• activities Reports disallowed Notification of
Review
funds to Completion*
• sections on
See
Treasury
•“standard” or
“early” closeout for
• details.
No further award expenditures are permitted.
*Generally, the Notification of Completion will be issued within one year of the POP end date (September 30, 2026)
or, in the case of early closeout, one year from the date the recipient submitted the Final Reports to Treasury.
3
Please see page 8 for more details.
4
If the recipient fails to submit the Final Reports, Treasury may proceed with administrative closeout of the HAF
award in accordance with 2 CFR 200.344(h) and the recipient will be deemed noncompliant with the HAF Award
Terms.
2
HAF Program Closeout Resource
After the submission (or submission deadline) of a recipient’s Final Reports, Treasury will
implement a Closeout Review of HAF awards (see page 9 for more details). Upon the
completion of closeout actions and resolution of any outstanding matters regarding the HAF
awards, Treasury will send a Notification of Completion.
“Early Closeout” Process
Recipients that complete all award objectives, including administrative actions (which include
any final operational activities), on their HAF award prior to September 30, 2026 may initiate
“early closeout” of their HAF awards. 5
Recipients initiate early closeout by submitting the Final Reports. Any final obligations must
be liquidated (expenses charged/billed against the award must be completed) and operational
activities associated with the award must be completed prior to submitting the Final Reports to
Treasury. Once the recipient has submitted the Final Reports to Treasury, the recipient may not
obligate or expend any remaining award funds for any purpose. Once the recipient submits the
Final Reports, the recipient is also no longer required to submit regular HAF quarterly and
annual reports. The recipient will remain subject to records retention and audit requirements (see
page 14 for more details).
Treasury has established a review process to help support a successful early closeout (Figure 2):
1. Recipient determines that it will soon be ready to initiate early closeout, forecasting
completion of award objectives and expenditures, including administrative actions like
final operational activities.
2. Recipient may request to closeout its award early through Treasury’s Portal.
3. Treasury will review the early closeout request and consult with the recipient, if
needed.
4. Treasury will notify and provide the recipient access to the Final Reports through
Treasury’s Portal, if Treasury determines that the recipient may proceed with early
closeout.
5
Per 2 CFR 200.340, the early closeout of a HAF award can be triggered by one of the following circumstances: (1)
termination of the HAF award by Treasury with the consent of the recipient prior to the end of the POP, in which
case the two parties must agree upon the termination conditions (see 2 CFR 200.340(a)(3)); (2) termination of the
HAF award by the recipient prior to the end date of the POP because it is no longer able to carry out the objectives
of the award (see 2 CFR 200.340(a) (4)); (3) termination of the HAF award by Treasury prior to the end date of the
POP because the recipient failed to comply with the requirements of the HAF Financial Assistance Agreement
(termination for cause, see 2 CFR 200.340(a)(1)); or (4) termination of the HAF award by Treasury prior to the end
date of the POP because the award no longer effectuates the program goals or agency priorities (termination for
convenience, see 2 CFR 200.340(a)(2)). In addition, early closeout can be triggered by the recipient when it has
expended all its award funds and completed all the objectives of the HAF award, including administrative actions,
prior to the end of the award POP. See 2 CFR 200.344.
3
HAF Program Closeout Resource
5. The recipient submits the Final Reports to Treasury to initiate the award closeout
process. Note that the recipient must continue to submit all regular quarterly and annual
reports until the Final Reports are submitted to Treasury. 6
In general, Treasury will begin to review the Final Reports within 90 days. Treasury will
work with the recipient to finalize the award closeout, generally within one year of the
submission of the Final Reports.
Figure 2: “Early Closeout” Process
Program POP
Recipient Recipient Treasury Treasury Recipient
•Forecasts •Requests •Reviews the •Grants the •Submits Final
completion of early closeout early closeout recipient access Reports to
award through request, which to the Final Treasury
objectives and Treasury's may include a Reports Treasury’s Early
Portal. consultation through Note: the recipient
expenditures,
must continue to
Closeout
including with the Treasury's
administrative recipient. Portal once
submit quarterly
and annual reports
Review Begins*
actions. Treasury until the
verifies the Final Reports are
submitted to
recipient is Treasury.
ready for
closeout.
Recipient may obligate and expend funds according to the various
No further award expenditures are
requirements of the HAF award; all obligations must be liquidated
permitted.
prior to submitting the Final Reports to Treasury.
*Please refer to Figure 1: General Closeout Process for process steps following the start of Treasury’s Closeout
Review process.
“Standard” Closeout Process and Timelines
The end of the award term marks the beginning of the “standard” closeout process for all
recipients of HAF awards that did not initiate early award closeout. Recipients will have 120
calendar days after September 30, 2026 to submit their Final Reports to Treasury via Treasury’s
Portal. Subrecipients must submit their final financial and performance reports, as applicable, to
the recipients no later than within 90 calendar days after September 30, 2026 (Figure 3).
Recipients must obligate award funds by September 30, 2026 to cover administrative costs
6
Treasury retains the right to reject the submission of a recipient’s Final Reports. In this case, the recipient must
continue to submit regular quarterly and annual reports through the end of the award POP.
4
HAF Program Closeout Resource
for closeout activities carried out during the liquidation period (October 1, 2026 - January 28,
2027). Obligations incurred by September 30, 2026 for allowable administrative and program
expenses must be paid in full prior to the end of the liquidation period and those transactions
must be included in the Final Reports, which must be submitted to Treasury by January 28,
2027. 7
Figure 3: “Standard Closeout” Process and Timeline
Liquidation Period
October 1, 2026 Recipient
Start of the
December 29, 2026
submits Treasury’s
January 28, 2027
liquidation period Subrecipient's final Final Closeout
Award POP following the end of financial and
the Period of Recipient's Final
performance reports Reports are due to Reports Review
Performance are due to recipient Treasury
(monitored by the
Begins*
recipient)
Recipient may Recipient may expend funds obligated by 9/30/2026 for
No further award expenditures
obligate and allowable administrative and program activities; all
are permitted.
expend funds. obligations must be liquidated prior to submitting the Final
Reports to Treasury.
*Please refer to Figure 1: General Closeout Process for process steps following the start of Treasury’s Closeout
Review process.
Standard Closeout Liquidation Period: Prohibited and Allowable Activities
After September 30, 2026, recipients are prohibited from using HAF award funds for the
following program activities:
• new obligations of funds to support administrative activities;
• assessment of applicant eligibility for HAF services and assistance;
• provision of counseling or legal services to homeowners;
• prospective assistance. Examples of prohibited prospective assistance expenditures
include but are not limited to:
o mortgage payment assistance to prospectively cover mortgage expenses for a
period beyond September 30, 2026;
7
Note that obligations incurred by subrecipients by September 30, 2026, must be paid in full within 90 calendar
days after September 30, 2026 for allowable administrative and program expenses or an earlier date as agreed upon
by subrecipient and recipient.
5
HAF Program Closeout Resource
o home repair costs where the home repair activities will occur after September 30,
2026.
Allowable administrative and program activities using HAF award funds must be obligated by
September 30, 2026 and may include:
• administrative expenses to support closeout activities (including administrative support
services and other direct and indirect expenses that support administrative activities
provided through staffing costs, subawards, contracts, preparation of Final Reports and
documents, etc.).
• payment processing for:
o approved HAF applicants; this would include payment processing for mortgage
reinstatement, utilities, or other allowable expenses incurred for a period prior to
September 30, 2026. Note that payment processing is prohibited for prospective
program assistance (e.g. prospective assistance for mortgage, utility bills, housing
counseling, etc.) that are incurred for a period after September 30, 2026.
o housing counseling or other services that occurred prior to September 30, 2026.
• documentation, assessment, and retention activities. See page 8 for details on obligating
and expending funds for this purpose.
• data security measures and protection of personally identifiable information, which may
include appropriate measures to ensure that the privacy of homeowners is protected and
provide confidentiality protections for data collected about any homeowners who are
survivors of intimate partner violence, sexual assault, or stalking.
• review and reconciliation of general ledger, accounting, reporting, bank reconciliation,
program policies, procedures, and controls to prevent fraud and improper payments,
which may involve follow-up with end-beneficiaries (e.g., homeowners, mortgage
servicers, utility companies) to reconcile documentation, as needed.
• continued internal auditing of approved applications for potential duplication of benefits
and associated remedial activities, as appropriate.
• single audits or program-specific audits required per 2 CFR 200 Subpart F, Audit
Requirements, if applicable.
6
HAF Program Closeout Resource
Preparing to Submit Final Reports
Recipients must submit Final Reports with cumulative financial, tangible personal property, and
performance information. For general reporting requirements and other reporting resources,
please see HAF Reporting webpage.
The following considerations and questions can help support an accurate report and clear
communications as recipients work through the closeout process:
• Does the budget in Treasury’s Portal accurately reflect your actual HAF award budget?
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.
• Does the data align with HAF program guidance?
For instance:
o Does the total amount expended for planning, community engagement, needs
assessment, and administrative expenses fall within the limit of 15% of the total
HAF award amount as set forth in the HAF Guidance? 8
o Does the total amount expended on housing counseling and legal services fall
within the limit of an aggregate amount up to 5% of the total HAF award amount
as set forth in the HAF Guidance? 9
• Do the Final Reports accurately reflect the recipient’s aggregate financial and
programmatic data throughout the award POP?
Recipients should check:
o whether total expenditures and obligations align with the total (net) award.
o whether there are any unobligated balances by the end of the POP or unliquidated
obligations by the end of the closeout period; if yes, see pages 10-13 for more
information about repaying of HAF award funds.
o the completeness and accuracy of the project data and participant demographics
(as applicable), as submitted in the Final Reports.
o to ensure that any tangible personal property, supplies, or other assets purchased
for the provision of allowed activities to support the housing stability of eligible
homeowners were installed prior to the expiration of the POP (in the case of
standard closeout) and prior to the recipient submitting the Final Reports (in the
case of early closeout). 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 September 30, 2026 to be
considered an eligible expense for standard closeout.
8
See HAF Guidance for information on the limit for planning, community engagement, needs assessment, and
administrative expenses (page 4).
9
See HAF Guidance for the limit on expenses for housing counseling and legal services pursuant to the HAF
Guidance (page 4).
7
HAF Program Closeout Resource
• Have you accounted for record retention requirements?
The HAF Financial Assistance Agreement stipulates that recipients must retain records
pertaining to the HAF award for “5 years after all funds have been expended or returned
to Treasury.” As such, Treasury determined that the start date for the record retention
period for HAF recipients is the submission date of their Final Reports to Treasury for
award closeout.
o Any administrative funds utilized to support record retention requirements:
• must be reasonable and consistent with the recipient’s policies and
procedures regarding the standard for retaining such records and the
amount of money the recipient would have paid for retaining its non-
federal records.
• must not exceed the limit for administrative costs which is 15% of the
total HAF award amount.
• should not be the cost of maintaining a financial system for its Federal
awards.
• must be obligated by September 30, 2026, end of the award POP and such
record retention obligation must be paid in full during the closeout period
(120 calendar days after September 30, 2026) and prior to the recipient’s
submission of its Final Reports to Treasury to the extent that the record
retention expense is within the 15% limit on administrative costs.
o Recipients must ensure that the method of record retention used for HAF award
records is secure and it sufficiently protects the personally identifiable
information and other sensitive information the recipients collected from
homeowners and others to implement their HAF award.
• Did you purchase equipment or supplies that will need to be reported?
All HAF recipients must report on tangible personal property (equipment and supplies)
acquired with HAF award funds during the award POP. 10 Recipients are responsible for
reporting on behalf of their subrecipients if their subrecipients used HAF award funds to
acquire equipment or supplies, or both.
Tangible personal property that needs to be reported in the Final Reports include:
o Acquired equipment with an acquisition cost of $10,000 or more.
o Residual inventory of unused supplies with a total aggregate fair market value
greater than $10,000.
Per the Uniform Guidance, 2 CFR 200.1, tangible personal property includes equipment
and supplies. It does not include copyrights, patents or securities. A computing device is
considered a supply if the acquisition cost is less than $10,000 per unit, regardless of the
length of its useful life.
10
On August 13, 2025, Treasury notified HAF Recipients that Treasury will apply the 2024 revised 2 CFR
200.313(e) regarding equipment disposition and 2 CFR 200.314(a) regarding supplies to all HAF awards.
8
HAF Program Closeout Resource
Consistent with the Uniform Guidance, 2 CFR 200.313(e)(1) and 2 CFR 200.314(a),
equipment acquired with HAF award funds with a current per unit fair market value of
$10,000 or less at the end of the award period of performance may be retained, sold, or
otherwise disposed of by HAF recipients with no further responsibility to Treasury.
Supplies acquired with HAF award funds with the total aggregate value of $10,000 or
less at the end of the award POP may also be retained by HAF recipients with no further
responsibility to Treasury. Additionally, Treasury permits recipients with equipment
with a per unit fair market value of more than $10,000 or unused supplies that have a
total aggregate value of more than $10,000 to be retained by the recipient if it is needed
for another federal award or for activities for non-federally funded programs or projects
for the government entities which have similar objectives as the HAF program.
Closeout Review of HAF Awards
After the submission (or submission deadline) of a recipient’s Final Reports, Treasury will
implement a Closeout Review of HAF awards, which may include:
• requesting verification of award closeout information from recipients,
• engaging recipients to resolve any issues found in their Final Reports; if a report requires
revision, Treasury may send instructions to revise and resubmit the Final Reports or an
Information Document Request (IDR) for the recipient to provide further clarity.
• notification of disallowed costs, as applicable.
• sending repayment instructions to recipients.
• initiating or proceeding with applicable remediation actions.
For each of these activities, Treasury will communicate specific instructions and deadlines to
recipients. Treasury may engage in further compliance activities, closeout review, and
communication with recipients, as needed and in alignment with applicable provisions of the
Uniform Guidance (2 CFR Part 200), Treasury’s guidance, and the terms and conditions of the
HAF Financial Assistance Agreement. If a recipient does not resolve outstanding issues,
Treasury will provide a formal opportunity to remedy the noncompliance prior to the recipient
being found noncompliant with the requirements set forth in the HAF Financial Assistance
Agreement.
Upon the completion of closeout actions and resolution of any outstanding matters regarding the
HAF awards, Treasury will send a Notification of Completion, informing each recipient that its
award has been closed out and no further action is required other than its compliance with certain
terms and conditions of the HAF award that extend beyond the closeout period. 11
11
Examples of the terms and conditions of the HAF FAA that extend beyond the closeout period include record
retention requirements, compliance-monitoring, and, if applicable, resolution of audit findings after award closeout.
9
HAF Program Closeout Resource
Repayment of HAF Award Funds
Following receipt and review of the recipient’s Final Reports, the recipient will enter into
“financial closeout” where Treasury reviews unliquidated obligations and unexpended award
funds to determine any adjustments following the submission of the Final Reports and/or
repayment amounts. Treasury will send a notice to the HAF recipient to verify financial
information through the Financial Closeout Confirmation Module to make any updates to the
total unobligated balances reported in the Final Reports. Reasons for updating unobligated
balances may include servicers or vendors returning funds after the HAF recipient submitted its
Final Reports to Treasury or Treasury determining that there are disallowed costs during its
Closeout Review of the Final Reports.
Figure 4: Calculating Final Returns to Treasury
10
HAF Program Closeout Resource
If a recipient owes money to Treasury due to, for instance, excess funds, unobligated balances,
improper use of funds, or other noncompliance issues under the HAF award, Treasury will send
repayment instructions and deadlines to make payments, as appropriate (also referred to as a
“pre-debt notice”), and if repayment is not made timely Treasury may seek other legally
available remedies. Recipients will have 30 calendar days to repay funds to avoid debt collection.
Once the recipient enters into debt collection, Treasury will issue a demand letter that outlines
escalating penalties for non-payment per 31 U.S.C. 3717 (see Figure 5).
Figure 5: Repayment Process
Treasury review of Final
Reports; IDRs requested as
Recipient submits
Final Reports.
needed to determine
repayment amounts during
Financial Closeout.
Treasury sends repayment Recipient returns funds in full
within 30 calendar days of pre-
instructions with return debt notice to avoid debt
deadline (pre-debt notice). collection.
DEBT COLLECTION AFTER 30 DAYS OF
NONPAYMENT,
If outstanding amount remains, Treasury will begin assessing
Treasury initiates debt collection and escalating penalties and
and issues a demand letter. interest on delinquent debts.
In general, the conclusion of financial closeout is often the last step in Treasury’s closeout
process and may be followed by Treasury sending the recipient a Notification of Completion
(see Figure 1). Please note that after the Notification of Completion, Treasury retains the right to
engage in a post-closeout adjustment to disallow costs and recover funds on the basis of a later
audit or other review pursuant to 2 CFR 200.345.
11
HAF Program Closeout Resource
If Treasury determines that a recipient is not in compliance with repayment instructions and/or
have other outstanding issues, Treasury may also put a “financial hold” on the recipient’s
HAF award, which may result in withholding of payments remaining on its other awards
under Treasury programs or take other enforcement actions. 12
Specific Repayment Situations
Earned Interest
Please also note that HAF awards are subject to the requirement to remit annually any earned
interest on the HAF award above $500 to the Department of Health and Human Services’
Payment Management System pursuant to 2 CFR 200.305(b)(9)(ii). Annually earned interest
refers to any interest earned by the recipient on the HAF award amount during the award period
of performance, for instance, interest earned while HAF award funds were held in a deposit
account at a bank.
If the annual earned interest is less than $500, the recipient may retain and use the funds for
administrative expenses. These funds may be used for administrative purposes until the recipient
submits the Final Reports. Once a recipient submits the Final Reports, any unexpended earned
interest remaining that is less than $500 must be returned to Treasury along with any unexpended
HAF award funds.
Figure 6: Repayment Requirements for Earned Interest
Type of Funds Open Awards Upon Submitting Final Reports
Earned interest > $500 Annually remit to DHHS PMS Remit to DHHS PMS System*
per year System
Earned interest < $500 May be retained for Must repay funds not expended as
per year administrative expenses administrative costs to Treasury along
with unexpended HAF award funds
*Please note that any interest earned on unobligated HAF award funds remaining with the recipient after
submission of its Final Reports must be returned to Treasury.
12
Per 2 CFR 200.339(a)
12
HAF Program Closeout Resource
Repayment of recovered or returned HAF Award Funds
Recipients receive recovered or returned award funds for several reasons. A recipient may
recover program income (e.g., homeowner loan repayments) or improper payments. HAF
recipients may also receive returned homeowner financial assistance from mortgage servicers,
utility companies, home repair contractors, or other end beneficiaries for a variety of reasons.
For most recovered or returned funds, recipients with open awards may redeploy any of these
funds for HAF program purposes. Once a recipient enters the closeout process, recipients must
plan to repay recovered or returned funds to Treasury, with an exception specific to recovered
program income. Recipients are not required to return recovered program income to Treasury
that they received after September 30, 2026. 13
Following the Notice of Completion, if HAF recipients have any further repayments to make to
Treasury, they should contact Treasury about the reason and the timing of the return of funds and
use the previously provided repayment instructions for any further repayments to Treasury,
unless otherwise instructed.
Figure 7: Repayment Requirements for Returned or Recovered Funds
Prior to September 30, 2026 After September 30, 2026
Type of Funds Open Awards Awards in All Awards
“Early Closeout”
(after HAF recipient submits
their Final Reports)
Returned funds
(e.g. homeowner
financial assistance May redeploy funds
returned to recipient by for eligible HAF Must repay funds to Must repay funds to
servicer, utility company, purposes Treasury Treasury
home repair contractor,
or other end
beneficiaries)
Recovered
Program Income May redeploy funds
Must repay funds to Not required to return
(e.g. homeowner loan for eligible HAF
Treasury funds to Treasury
repayments (principal purposes
and interest))
Other recovered funds May redeploy funds
Must repay funds to Must repay funds to
(e.g., recipient recovers for eligible HAF
Treasury Treasury
improper payments, etc.) purposes
13
Recipients that initiate early closeout must return recovered program income to Treasury between the period that
they submit their Final Reports, initiating “early closeout,” and the end of the POP on September 30, 2026. After
September 30, 2026, all recipients of HAF awards are not required to return recovered program income to Treasury.
13
HAF Program Closeout Resource
Section II. Post-Closeout Compliance Reminders
Following the submission of the Final Reports and the Notification of Completion, Treasury may
continue to engage in further compliance activities, closeout-review, and communication with
recipients, as needed and in alignment with applicable provisions of the Uniform Guidance (2
CFR Part 200), Treasury’s guidance, and the terms and conditions of the HAF Financial
Assistance Agreement. The following is a non-exhaustive list of post-closeout recipient
responsibilities.
Records Retention & Documentation
Per the HAF Financial Assistance Agreement, financial records, supporting documents,
statistical records, and all other non-Federal entity records pertinent to the HAF award must be
retained for a period of five years after all funds have been expended or returned to Treasury. 14
As such, Treasury determined that the start date for the record retention period for HAF
recipients is the submission date of their Final Reports to Treasury for award closeout. If an
audit, litigation, or other action involving the HAF records starts before the end of the
appropriate retention period of five years, the records should be maintained until the end of the
appropriate retention period or until the audit, litigation, or other action is completed, whichever
is later.
Documentation of Compliance with Federal Civil Rights Statutes and Regulations:
Recipients are required to comply with federal civil rights statutes and regulations, including
Title VI of the Civil Rights Act of 1964, Section 504 of the Rehabilitation Act of 1973, the Age
Discrimination Act of 1975, and the Fair Housing Act (Title VIII of the Civil Rights Act of
1968) as outlined in the HAF Financial Assistance Agreement executed by the recipients in
connection with their HAF awards. Note: Treasury does not impose nondiscrimination
requirements on Tribal governments beyond what would otherwise apply under federal law.
Information about the recipients’ civil rights obligations can be found in Treasury’s Civil Rights
Toolkit. 15
Audit Requirements
Thoughtful and thorough work related to award closeout can help support an accurate and
effective audit. Audit activities may fall outside of the timelines associated with closeout
activities. However, recipients with open awards may use HAF award funds towards single audit
or program-specific audit costs, as applicable and within the administrative costs limit, for
14
Please note that 2 CFR 200.334 provides that pass-through entities that receive federal awards must not impose
any other record retention requirements on non-Federal entities, except those outlined in 2 CFR 200.334(a)-(f).
15
On March 4, 2026, Treasury rescinded its Guidance to Federal Financial Assistance Recipients Regarding Title VI
Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons for consistency
with Executive Order 14224, titled, “ Designating English as the Official Language of the United States and dated
March 1, 2025, which revoked Executive Order 13166, titled Improving Access to Services for Persons with
Limited English Proficiency. See 70 Fed. Reg. 6067. As such, Treasury revised the HAF Program Closeout
Resource on March 30, 2026 to remove all references to Treasury’s rescinded guidance regarding language access
services to Limited English Proficient Persons.
14
HAF Program Closeout Resource
annual single or program-specific audits, as applicable, until fiscal year 2026 and in accordance
with 2 CFR 200.425 and 2 CFR Part 200, Subpart F – Audit Requirements, as long as the costs
are obligated before the end of the award POP and expended within 120 calendar days (or 90
calendar days in the case of subrecipients) after September 30, 2026 per 2 CFR 200.344(a).
Please note that, in the case of a recipient engaging in early closeout, HAF award funds may
only be expended to support audit activities that occur after the recipient submits its Final
Reports to Treasury if the recipient expended HAF award funds prior to submitting the Final
Reports and during its current fiscal year that will be audited.
Detailed information regarding single audits and program-specific audits can be found in 2 CFR
Part 200, Subpart F, Audit Requirements. Here is some basic information regarding auditee
responsibilities (2 CFR 200.508) to help recipients plan:
• Recipients that expend $1,000,000 or more in federal awards during their fiscal year that
begins on or after October 1, 2024 are required to undergo either a single audit or
program-specific audit for that fiscal year. 16
• Recipients are responsible for procuring or otherwise arranging for audits and ensuring
the auditor has the necessary experience to perform this type of audit in accordance with
2 CFR 200.509.
o Information with instructions for how auditors must perform these audits can be
found at 2 CFR 200.514-200.520 and in the HAF 2024 Compliance Supplement
published by the Office of Management and Budget.
o Recipients are advised to continue to check the HAF Guidance page on
Treasury’s website for additional compliance resources, e.g., Compliance
Supplements.
• Recipients must prepare their financial statements and other materials required by their
auditors to perform their audits and provide the auditors with all necessary
documentation (e.g., records).
• Recipients are expected to take prompt corrective action following any audit findings.
• Recipients must submit and certify their single audit reports to Federal Audit
Clearinghouse “within the earlier of 30 calendar days after receipt of an auditor’s
report(s), or nine months after the end of the audit period” per 2 CFR 200.512(a)(1). The
audit period is a recipient’s fiscal year.
• Recipients with audit findings must work with Treasury, as appropriate, to resolve those
findings.
16
With the 2024 revision of 2 CFR Part 200, the expenditure threshold that requires a recipient to conduct a single
audit or a program-specific audit increased from $750,000 to $1,000,000 in federal funds for (see 2 CFR 200.501).
This new threshold applies to recipients whose fiscal year begins on or after October 1, 2024.
15
HAF Program Closeout Resource
APPENDIX A: Definitions
Administrative activities generally include activities to support closing out the award in
accordance with 2 CFR 200.344, including, but not limited, to administrative support services
and other direct and indirect expenses that support administrative activities provided through
staffing costs, subawards, contracts, preparation of Final Reports and documents, etc.
Administrative closeout occurs if the Final Report has not been submitted and Treasury initiates
the closeout process on behalf of the participant, per 2 CFR 200.344 (h)-(i).
Closeout refers to the process by which the federal awarding agency or pass-through entity
determines that the participant (or subrecipient) has completed all applicable administrative
actions and required work of the federal award have been completed. And therefore, the federal
awarding agency or pass-through entity takes actions as described in 2 CFR 200.344.
Financial Closeout refers to the review of unliquidated obligations and unexpended award funds
by the end of the award term POP and closeout period. Financial closeout determines whether
that amount will be repaid to Treasury and includes recoupment of any disallowed or ineligible
costs.
Participant/recipients means the eligible entities, states, the District of Columbia, U.S.
territories, Indian Tribes, Tribally Designated Housing Entities, and the Department of Hawaiian
Home Lands that received a HAF award under the Homeowner Assistance Fund program
pursuant to section 3206 of the American Rescue Plan Act, 2021. In the case of this document,
"recipient" and "participant" may be used interchangeably. These terms do not include
subrecipients (e.g. vendor, nonprofit partner, etc.) or beneficiaries of the award (e.g.
homeowners, mortgage servicers, utility companies, etc.).
Period of performance means the total estimated time during which the recipient and
subrecipient must perform and complete the work authorized under the Federal award; it is the
interval between the start of an initial federal award and the planned end date.
Post-closeout adjustment describes activities that occur after a federal awarding agency closes
out an award pursuant to 2 CFR 200.345. These activities include: (1) The right of the federal
awarding agency or pass-through entity to disallow costs and recover funds on the basis of a later
audit or other review; (2) The requirement for the recipient to return any funds due as a result of
later refunds, corrections, or other transactions including final indirect cost rate adjustments; (3)
The ability of the federal awarding agency to make financial adjustments to a previously closed
award such as resolving indirect cost payments and making final payments; (4) Audit
requirements; (5) Property management and disposition requirements; and (6) Record retention
requirements.
Remediation actions refer to activities pursued to correct a recipient’s noncompliance with
statutes, regulations, or the terms and conditions of their award agreement.
16
HAF Program Closeout Resource
Subrecipient means an entity that receives a subaward from a pass-through entity (e.g. a HAF
recipient) to carry out part of a federal award; but does not include an individual that is a
beneficiary (e.g. homeowners, mortgage servicers, utility companies, etc.) of such award.
Unexpended obligations means the amount of funds that have been obligated by the recipient
under a federal award but not paid; may also be referred to as unliquidated obligations.
Unobligated balance means the amount of funds under a federal award that the recipient has not
obligated.
17
File and source
- File
- TREAS-HAF_Closeout_Resource.pdf
- Size
- 486,589 bytes
- SHA-256
- 4e31eb125c4a10762e465d591dc2750651d658d50f55737a60349d84068a78d2
- Our copy
- TREAS-HAF_Closeout_Resource.pdf
- Original
- home.treasury.gov