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Treasury, HAF Guidance on Participant Compliance and Reporting Responsibilities

Summary

Treasury's compliance and reporting guidance for Homeowner Assistance Fund (HAF) participants, the eligible entities named in Section 3206 of the American Rescue Plan Act of 2021, dated May 9, 2022 and revised December 22, 2025. Participants are accountable for their Subrecipients and must run internal controls to minimize the risk of fraud, waste and abuse. Eligible participants include the Department of Hawaiian Home Lands, States (with the District of Columbia and U.S. territories) and Tribes. The change log records due dates adjusted for the Presidents' Day holiday (December 22, 2025), references to Executive Order 13985 on racial equity removed (December 9, 2025), and reporting fields updated as mandated by Executive Order 14168 (July 15, 2025). A January 12, 2024 update removed the 2026 quarter 3 report and revised the final report due date.

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“Treasury, HAF Guidance on Participant Compliance and Reporting Responsibilities.” Original at home.treasury.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/treasury-haf-guidance-on-participant-compliance-and-reporting-responsi-504ba0b0d2/, SHA-256 fea5c1f96dbcf1f97f8b313b919788b400e86df668a254e7643612a76b99a72f.

Full text

Homeowner Assistance Fund:
Guidance on Participant Compliance and Reporting
Responsibilities

May 9, 2022 (Revised December 22, 2025)




For More Information: Please visit www.treasury.gov/HAF
For Media Inquiries: Please contact the U.S. Treasury Press Office at (202) 622-2960
For General Inquiries: Please email HAF@treasury.gov for additional information
                                Homeowner Assistance Fund
     Guidance on Participant Compliance and Reporting Responsibilities Change Summary
         Section                                              Changes
    December 22, 2025 Updates
     Part 2: Quarterly         •    Adjusted due date for 2024 quarter 4 and 2025 quarter 4
        Reporting                   reports to accommodate Presidents’ Day holiday
    December 9, 2025 Updates
     Part 1: General           •    Removed references to former Executive Order 13985, “On
       Guidance                     Advancing Racial Equity and Support for Underserved
                                    Communities through the Federal Government.”
•   July 15, 2025 Updates
       Throughout              •    Updates to reporting fields mandated by the President’s
                                    January 20, 2025 Executive Order 14168 titled, “Defending
                                    Women From Gender Ideology Extremism and Restoring
                                    Biological Truth to the Federal Government.”
    May 2, 2025 Updates
     Part 1: General           •    Revised Annual Single Audit Requirements
       Guidance
      Single Audit
     Requirements
    January 12, 2024 Updates
     Part 2: Quarterly         •    Removed requirement for 2026 quarter 3 report submission
        Reporting                   and revised due date for final report submission
      Part 2: Annual           •    Revised period covered and due date for final report
      Performance                   submission
         Report
    July 15, 2022 Updates
     Part 2: Quarterly         •    Revised time frame for Quarterly Reporting by Tribal
        Reporting                   governments with allocations less than $5 Million and
                                    Department of Hawaiian Home Lands (footnote 13).
      Part 2: Annual           •    Revised time frames for Annual Reports.
      Performance
         Report
       Appendix 2              •    Removed Region disaggregate category.
    May 11, 2022 Updates
     Part 1: Qualified         •    Removed Qualified Expense #12 which listed out ground-rent
       Expenses                     separately.
    Public Comment Adjudication – May 9, 2022
                               •    Replaced “HAF-funded Program” with “HAF Program.”
       All Sections            •    Clarified expectation that collection of Race data allows for
                                    Homeowners to select multiple races.



                                       Homeowner Assistance Fund:
                       Guidance on Participant Compliance and Reporting Responsibilities
                           •    Added clarification between Monetary HAF Assistance and
Part 1: Definitions
                                Non-Monetary HAF Assistance.
                           •    Added language to Counseling or Education Qualified
                                Expense to tie to updated Guidance language published on
Part 1: Qualified
                                February 24, 2022.
  Expenses
                           •    Addressed Lot-rent on Manufactured Homes as a Qualified
                                Expense.
 Part 1: Uniform
                           •    Added clarification on the de minimis rate for administrative
 Administrative
                                expenses.
 Requirements
                           •    Updated reporting timeline.
Part 2: Quarterly          •    Clarified time frames covered by Quarterly Reports.
     Report                •    Clarified guidance in Programmatic Information
                                Requirements.
 Part 2: Annual
                           •    Updated Annual Performance Reporting timeline.
 Performance
    Report                 •    Added language to Civil Rights Compliance section.

                           •    Added “Sub-Category Not Collected” to the Race
   Appendix 1
                                disaggregate category.
                           •    Added “Greater than 150%” to the Area Median Income
                                disaggregate category.
   Appendix 2
                           •    Consolidated Housing Type Single Family Home
                                Detached/Attached category to Single Family Home.
                           •    Added language related to Lot-rent and what program design
   Appendix 3
                                elements Lot-rent could impact.




                                   Homeowner Assistance Fund:
                   Guidance on Participant Compliance and Reporting Responsibilities
Table of Contents
   Definitions ......................................................................................................................... 2
Part 1: General Guidance ..................................................................................................... 4
   Guiding Principles ............................................................................................................. 5
   Eligible Participants ........................................................................................................... 5
   Qualified Expenses............................................................................................................ 5
   Reimbursable Expenses Incurred Prior to HAF Award ...................................................... 7
   Reporting........................................................................................................................... 7
   Uniform Administrative Requirements................................................................................ 7
   Other Compliance Obligations ......................................................................................... 10
Part 2: Reporting Requirements and Deadlines .................................................................. 12
   Quarterly Report .............................................................................................................. 12
      Executive Summary ..................................................................................................... 12
      Quarterly Reporting...................................................................................................... 12
   Annual Performance Report ............................................................................................ 17
      Executive Summary ..................................................................................................... 17
      Annual Performance Reporting .................................................................................... 18
Appendix 1 – Race, Ethnicity and Sex Categories .............................................................. 19
Appendix 2 – Targeting Categories ..................................................................................... 20
Appendix 3 – Program Design Element Categories ............................................................ 22




                                           Homeowner Assistance Fund:
                           Guidance on Participant Compliance and Reporting Responsibilities

                                                                    1
              Homeowner Assistance Fund
     Guidance on Recipient Compliance and Reporting
                    Responsibilities
On March 11, 2021, the American Rescue Plan Act was signed into law, and established the
Homeowner Assistance Fund (“HAF”) program. This program provides funding to eligible
entities 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.

This guidance provides additional detail and clarification for each participant’s compliance and
reporting responsibilities under the HAF program, and should be read in concert with the HAF
Financial Assistance Agreement, the authorizing statute, the Homeowner Assistance Fund
Guidance (the “HAF Guidance”) and other regulatory and statutory requirements, including
regulatory requirements under the Uniform Guidance (2 CRF Part 200). Please see the
Assistance Listing in SAM.gov under assistance listing number (formerly known as CFDA
number), 21.026 for more information.

Please Note: This guidance document applies to the HAF program only. This guidance
contains two parts: Part 1 addresses general guidance and Part 2 addresses reporting
requirements and deadlines.


Definitions

Award Date means the date the HAF participant signed the HAF Financial Assistance
Agreement.

Delinquency(ies) means an obligation on which a Homeowner was past due on any housing
related HAF qualified expense.1

Eligible Entity2 means (1) a State (2) the Department of Hawaiian Home Lands, (3) each
Indian Tribe (or, if applicable, the tribally designated housing entity of an Indian Tribe) that
was eligible for a grant under Title I of the Native American Housing Assistance and Self
Determination Act of 1996 (25 U.S.C. 4111 et seq.) for fiscal year 2020, and (4) any Indian
Tribe that opted out of receiving a grant allocation under the Native American Housing Block
Grants program formula in fiscal year 2020.

Expenditure/Expended means any HAF assistance that has been spent by a HAF participant
and/or Subrecipient. Please note, cumulative Expenditures cannot exceed cumulative
Obligations.

Financial hardship3 means a material reduction in income or material increase in living
expenses associated with the coronavirus pandemic that has created or increased a risk of


1 Reference definition published in HAF Guidance published on August 2, 2021 (Updated November

12, 2021). Refer to the qualified expenses noted in the HAF Guidance.
2 Reference section published in HAF Guidance published on August 2, 2021 (Updated November 12,

2021)
3 Reference definition published in HAF Guidance published on August 2, 2021 (Updated November

12, 2021)



                                   Homeowner Assistance Fund:
                   Guidance on Participant Compliance and Reporting Responsibilities

                                                  2
mortgage delinquency, mortgage default, foreclosure, loss of utilities or home energy services,
or displacement for a homeowner.

HAF participant4 means an Eligible entity that receives funds from the HAF.

HAF assistance means any assistance provided by the HAF program, whether through funds
received by the HAF program for qualified expenses or through services made available by
the HAF program.

       Monetary HAF Assistance means HAF assistance in the form of money that was
       provided to Homeowners or on behalf of Homeowners to financial institutions, utility
       providers, and taxing authorities or other third-party payees under a HAF Program.
       Homeowners that received both Monetary and Non-monetary Assistance should be
       counted once as having received Monetary HAF Assistance.

       Non-monetary HAF Assistance means HAF assistance in any form other than money
       that was provided to Homeowners under a HAF Program (e.g., housing counseling or
       referral to legal services, etc.). Only Homeowners that received Non-monetary HAF
       Assistance without any Monetary HAF Assistance are to be counted as having
       received Non-Monetary HAF Assistance.

HAF application means an application submitted by the unique Homeowner to the HAF
participant or Subrecipient used to determine eligibility to receive HAF assistance for qualified
expenses.

Homeowner means an individual who applied and/or receives funds from the HAF participant
or Subrecipient to pay for a singular qualified expense (i.e., if a Homeowner receives HAF
assistance for more than one qualified expense category, they are counted for more than one
qualified expense category).

       In some places, the Interim Guidance requires that you provide the number of unique
       Homeowners. Unique Homeowners are only counted one time even if they applied and
       or/received funding for more than one qualified expense category.

Maximum conforming loan limit5 means the applicable limitation governing the maximum
original principal obligation of a mortgage secured by a single-family residence, a mortgage
secured by a two-family residence, a mortgage secured by a three-family residence, or a
mortgage secured by a four-family residence, as determined and adjusted annually under
section 302(b)(2) of the Federal National Mortgage Association Charter Act (12 U.S.C.
1717(b)(2)) and section 305(a)(2) of the Federal Home Loan Mortgage Corporation Act (12
U.S.C. 1454(a)(2)).

Obligation/Obligated means an order placed for property and services, contracts and
subawards made, and similar transactions that require payment (see 2 CFR § 200.1.).
Obligated funds include funds that have been Expended.

   •   Examples of obligated funds include: HAF funds that have been committed, pledged,
       or otherwise promised, in writing, to a specific individual or entity as part of a HAF
       program; HAF funds that have been set aside to cover obligations arising from loan
       guarantees; HAF funds that have been committed, pledged, or otherwise promised, in



4 Reference definition published in HAF Guidance published on August 2, 2021 (Updated November

12, 2021)
5 Reference definition published in HAF Guidance published on August 2, 2021 (Updated November

12, 2021)

                                   Homeowner Assistance Fund:
                   Guidance on Participant Compliance and Reporting Responsibilities

                                                  3
        writing, as part of a transaction; and HAF funds that have been committed, pledged,
        or promised, in writing, for allowable administrative expenses (e.g., an executed
        contract for services).

Program Design Elements are the following: Mortgage Payment Assistance, Financial
Assistance, Mortgage Principal Reduction, Facilitating Interest Rate, Payment Assistance
Utilities, Payment Assistance Internet, Payment Assistance Insurance, Payment Assistance
Fees, Payment Assistance Loans, Payment Assistance Taxes, Measures Preventing
Displacement, Counseling or Education and Legal Services which align to eight of the qualified
expenses (excludes administrative expenses).

Socially Disadvantaged Individual6 are those whose ability to purchase or own a home has
been impaired due to diminished access to credit on reasonable terms as compared to others
in comparable economic circumstances, based on disparities in homeownership rates in the
HAF participant’s jurisdiction as documented by the U.S. Census. The impairment must stem
from circumstances beyond their control. Indicators of impairment under this definition may
include being a (1) member of a group that has been subjected to racial or ethnic prejudice or
cultural bias within American society, (2) resident of a majority-minority Census tract; (3)
individual with limited English proficiency; (4) resident of a U.S. territory, Indian reservation, or
Hawaiian Home Lands, or (5) individual who lives in a persistent-poverty county, meaning any
county that has had 20% or more of its population living in poverty over the past 30 years as
measured by the three most recent decennial censuses. In addition, an individual may be
determined to be a socially disadvantaged individual in accordance with a process developed
by a HAF participant for determining whether a homeowner is a socially disadvantaged
individual in accordance with applicable law, which may reasonably rely on self-attestations.

State means any state of the United States, the District of Columbia, the Commonwealth
of Puerto Rico, Guam, American Samoa, the United States Virgin Islands, and the
Commonwealth of the Northern Mariana Islands.

Subrecipient as defined in the Uniform Guidance (see 2 CFR § 200.1).


Part 1: General Guidance
This section provides an orientation for HAF participants regarding their compliance
responsibilities and Treasury’s expectations and recommended best practices where
appropriate under the HAF program.

HAF participants are the eligible entities identified in Title III, Subtitle B, Section 3206 of the
American Rescue Plan Act of 2021 (the “HAF statute”) and the HAF Guidance that receive a
HAF award. Subrecipients under the HAF program (“Subrecipients”) are entities that receive
a subaward from a HAF participant to carry out the purposes of the HAF award on behalf of
the HAF participant.

HAF participants are accountable to Treasury for oversight of their Subrecipients, including
ensuring the Subrecipients comply with the HAF statute, HAF Financial Assistance
Agreement, HAF Guidance, applicable, federal statutes, regulations, and reporting
requirements.




6 Reference definition published in HAF Guidance published on August 2, 2021 (Updated November

12, 2021)



                                    Homeowner Assistance Fund:
                    Guidance on Participant Compliance and Reporting Responsibilities

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Guiding Principles

There are several guiding principles for developing effective compliance regimes under HAF:

•   HAF participants are responsible for ensuring HAF award funds are used for approved
    purposes, and developing an internal control program designed to minimize the risk of
    fraud, waste, and abuse associated with their HAF award;
•   Many HAF programs respond to the COVID-19 public health emergency and meet urgent
    community needs. Swift and effective implementation is vital, and Participants must
    balance facilitating program access and maintaining a robust documentation and
    compliance regime; and
•   Transparency and public accountability for HAF awards and use of such funds are critical
    to upholding program integrity and trust in all levels of government, and HAF awards
    should be managed consistent with Administration guidance per Memorandum M-21-20
    and Memorandum M-20-21.

Eligible Participants
The HAF Statute and HAF Guidance identifies the Department of Hawaiian Home Lands,
States (defined to include the District of Columbia and U.S. territories), and Tribes or their
tribally designated housing entity (TDHE), as the entities eligible to receive a HAF award.
    •   Eligible states (“States”) are any state of the United States, the District of Columbia,
        the Commonwealth of Puerto Rico, Guam, American Samoa, the United States Virgin
        Islands, and the Commonwealth of the Northern Mariana Islands.7
    •   The Department of Hawaiian Home Lands.8
    •   Eligible Tribal Governments (“Tribal Governments”) are Indian Tribes (or, if applicable,
        the tribally designated housing entity of an Indian Tribe) that were eligible for a grant
        under Title I of the Native American Housing Assistance and Self-Determination Act of
        1996 (25 U.S.C. 4111 et seq.) for fiscal year 2020 or Indian Tribes that opted out of
        receiving a grant allocation under the Native American Housing Block Grants
        program formula in fiscal year 2020.9
HAF participants may award funds to Subrecipients, such as other levels or units of
government (e.g., a municipality), non-profits, or private entities.

Qualified Expenses

HAF participants may use their HAF award funds only for the following types of qualified
expenses that are 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:
          1. mortgage payment assistance;
          2. 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;
          3. mortgage principal reduction, including with respect to a second mortgage provided
          by a nonprofit or government entity;
          4. facilitating mortgage interest rate reductions;
          5. payment assistance for:


7 Title III, Subtitle B, Section 3206(b)(7) of the American Rescue Plan Act of 2021.
8 HAF Guidance published on August 2, 2021 (Updated November 12, 2021).
9 HAF Guidance published on August 2, 2021 (Updated November 12, 2021).




                                     Homeowner Assistance Fund:
                     Guidance on Participant Compliance and Reporting Responsibilities

                                                    5
           a. homeowner’s utilities, including electric, gas, home energy (including firewood
           and home heating oil), 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;
       6. payment assistance for delinquent property taxes to prevent homeowner tax
       foreclosures;
       7. measures to prevent homeowner displacement, such as home repairs to maintain
       the habitability of a home, including the reasonable addition of habitable space to
       alleviate overcrowding, or assistance to enable households to receive clear title to their
       properties;
       8. counseling or educational efforts by housing counseling agencies approved by HUD
       or a 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% of the funding from the HAF received
       by the HAF participant;
       9. 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 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);
       10. 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% of the funding from the HAF
       received by the HAF participant;
       11. 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.
       12. 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; and
       13. 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.

Arrearages of qualified expenses are eligible for purposes of the HAF program regardless of
the date they were incurred, including if they arose before January 2020. Funding from the
HAF program may not be used for any use other than those provided for in this section. To
the extent that HAF participants use their HAF award funds to supplement other loss-
mitigation efforts, Treasury encourages participants to avoid using HAF award funds in a
manner that replaces other loss-mitigation resources that would otherwise be available.




                                   Homeowner Assistance Fund:
                   Guidance on Participant Compliance and Reporting Responsibilities

                                                  6
Reimbursable Expenses Incurred Prior to HAF Award
HAF participants may use their HAF award funds to cover qualified expenses that they
incurred during the period that began on January 21, 2020 (or the date of initial qualifying
administrative and housing activity). See number #9 in Qualified Expenses above for terms
regarding reimbursement of funds 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.

Reporting
HAF participants will be required to submit quarterly reports until September 30, 2026, and
final reports are due no later than 120 calendar days after the end of the period of performance
on September 30, 2026.

The reports will include financial data, types of programs funded, program design element
information, and other information regarding a HAF participant’s utilization of the award funds.

 HAF participants will also be required to submit an Annual Performance Report to Treasury
regarding the impact of the HAF award funds and the overall HAF program.

Refer to Part 2 for further details.


 Assistance Listing
 The Assistance Listing for the Homeowners Assistance Fund was published August 12,
 2021 on SAM.gov under Assistance Listing Number (“ALN”), formerly known as CFDA
 Number, 21.026.
 The assistance listing includes helpful information including program purpose, statutory
 authority, eligibility requirements, and compliance requirements for Participants. The ALN
 is the unique 5-digit number assigned to identify a federal assistance listing and can be
 used to search for federal assistance program information, including funding
 opportunities, spending on USASpending.gov, or audit results through the Federal Audit
 Clearinghouse.
 Participants must use ALN 21.026 for all financial accounting, subawards, and
 associated program reporting requirements for the HAF awards.




Uniform Administrative Requirements

The HAF award funds are generally subject to the requirements set forth in the Uniform
Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2
CFR Part 200 (the “Uniform Guidance”). In all instances, a HAF participant should review the
Uniform Guidance requirements applicable to their organization’s use of HAF award funds,
and HAF programs. HAF participants should consider how and whether certain aspects of the
Uniform Guidance apply.

1. Allowable Activities. Each HAF participant should review program requirements and the
   HAF participant’s Financial Assistance Agreement, HAF statute, and HAF guidance to
   determine and record eligible uses of HAF award funds. Per 2 CFR 200.303, a HAF
   participant must develop and implement effective internal controls to ensure that funding




                                    Homeowner Assistance Fund:
                    Guidance on Participant Compliance and Reporting Responsibilities

                                                   7
   decisions under the HAF award constitute eligible uses of funds, and document
   determinations.


2. Allowable Costs/Cost Principles. As outlined in the Uniform Guidance at 2 CFR Part
   200, Subpart E regarding Cost Principles, allowable costs are based on the premise that
   a HAF participant is responsible for the effective administration of Federal awards,
   application of sound management practices, and administration of Federal funds in a
   manner consistent with the program objectives and terms and conditions of the award.
   HAF participants must implement robust internal controls and effective monitoring to
   ensure compliance with the Cost Principles, which are important for building trust and
   accountability.
   HAF award funds may be, but are not required to be, used along with other funding sources
   for a given project. Note that HAF award funds may not be used for a non-Federal cost
   share or match where prohibited by other Federal programs, e.g., funds may not be used
   for the State share for Medicaid.10
   a. Administrative costs: 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, must not exceed 15% of the funding
      from the HAF received by the HAF participant.

       Consistent with 2 C.F.R. § 200.414(f), eligible applicants that do not have a current
       negotiated indirect cost rate may elect to charge indirect costs to an award pursuant
       to a de minimis rate of ten percent of the modified total direct costs (MTDC) for
       program administration.

       As described in 2 C.F.R. § 200.403(d), costs must be accorded consistent treatment.
       A cost may not be assigned to a Federal award as a direct cost if any other cost
       incurred for the same purpose in like circumstances has been allocated to the
       Federal award as an indirect cost.

       A HAF participant may only permit its subrecipient to use the 10% de minimis indirect
       cost rate or use another indirect cost rate based on a prior negotiated rate between a
       different Pass-through entity and the same subrecipient, if the subrecipient does not
       currently have a Federally approved negotiated indirect cost rate agreement (NICRA)
       from its cognizant agency for indirect costs (see 2 CFR 200.332(a)(4)). However, the
       HAF participant and its subrecipient’s direct and indirect administrative expenses
       combined with their expenses for planning, community engagement, and needs
       assessment may not exceed 15% of the total HAF award amount per the HAF
       guidance and HAF reporting guidance. Therefore, a HAF participant may apply its
       NICRA (or if applicable, the 10% de minimis rate) and its subrecipient may apply
       another indirect cost rate per 2 CFR 200.332(a)(4)(A) to charge indirect costs to the
       HAF award, but only to the extent that the total amount charged pursuant to that
       indirect rate, their direct administrative expenses, and expenses for planning,
       community engagement, and needs assessment does not exceed 15% of the total
       amount of the HAF award.


3. Eligibility. Under this program, HAF participants are responsible for ensuring funds are
   used for eligible purposes. Generally, HAF participants must develop and implement


10 See 42 CFR 433.51 and 45 CFR 75.306.




                                  Homeowner Assistance Fund:
                  Guidance on Participant Compliance and Reporting Responsibilities

                                                 8
   policies and procedures, and record retention, to determine and monitor implementation
   of criteria for determining the eligibility of beneficiaries and / or Subrecipients. HAF
   participants, and if applicable, the Subrecipient(s) administering a program on behalf of
   the HAF participant, will need to maintain procedures for obtaining information evidencing
   a given beneficiary, Subrecipient, or contractor’s eligibility, including a valid SAM.gov
   registration. Implementing risk-based due diligence for eligibility determinations is a best
   practice to augment your organization’s existing controls.


4. Equipment and Real Property. Any purchase of equipment or real property with HAF
   award funds must be consistent with the Uniform Guidance at 2 CFR Part 200, Subpart D.
   Equipment and real property improved under this program must be used for the originally
   authorized purpose. Consistent with 2 CFR 200.311 and 2 CFR 200.313, any equipment
   acquired, or real property improved with HAF funds shall vest in the non-Federal entity.
   Any acquisition and maintenance of equipment or improvement to real property must also
   comply with relevant laws and regulations.


5. Matching, Level of Effort, Earmarking. There are no matching, level of effort, or
   earmarking compliance responsibilities associated with the HAF award. HAF award funds
   may only be used for non-Federal match in other programs where costs are eligible under
   both HAF and the other program use of such funds is not prohibited by the other program.


6. Period of Performance. The period of performance under the HAF award begins on the
   date the Financial Assistance Agreement was executed and ends on September 30, 2026.
   Any funds not used during this period must be returned to Treasury as part of the award
   closeout process pursuant to 2 CFR 200.344(d).

7. Procurement, Suspension & Debarment. HAF participants are responsible for ensuring
   that any procurement using HAF award funds must comply with the procurement
   standards set forth in the Uniform Guidance at 2 CFR 200.317 through 2 CFR 200.327, as
   applicable. HAF participants must have and use documented procurement procedures
   consistent with the standards outlined in 2 CFR 200.317 through 2 CFR 200.327, as
   applicable. The Uniform Guidance requires an infrastructure for competitive bidding and
   contractor oversight, including maintaining written standards of conduct and prohibitions
   entering into contracts or subawards with suspended or debarred parties.


   Program Income. Funding from the HAF may not be used for any use other than qualified
   expenses and reimbursements. HAF participants may use program income earned during
   the period of performance as a result of implementing the objectives of the HAF award for
   eligible purposes outlined in this guidance. “Program income” is defined in 2 C.F.R. § 200.1
   as gross income earned by a non-federal entity that is generated directly by a supported
   activity or earned as a result of the federal award during the period of performance except
   as provided by 2 C.F.R. § 200.307(f). Program income includes income from fees for
   services performed, the use or rental of real or personal property acquired under federal
   awards, and principal and interest on loans made with federal award funds.


8. Reporting. All HAF participants receiving federal funds must complete financial,
   performance, and compliance reporting as required and outlined in Part 2 of this guidance.
   Expenditures may be reported on a cash or accrual basis, as long as the methodology is
   disclosed and consistently applied. Reporting must be consistent with the definition of
   expenditures pursuant to 2 CFR 200.1. HAF participants should appropriately maintain



                                  Homeowner Assistance Fund:
                  Guidance on Participant Compliance and Reporting Responsibilities

                                                 9
   accounting records for compiling and reporting accurate, compliant financial data, in
   accordance with appropriate accounting standards and principles.

   In addition, where appropriate, HAF participants must establish controls to ensure
   completion and timely submission of all mandatory performance and/or compliance
   reporting. For a full overview of HAF participant reporting responsibilities see Part 2 of this
   guidance.

9. Subrecipient Monitoring. HAF participants that are pass-through entities as defined
   under 2 CFR 200.1 are required to manage and monitor their Subrecipients to ensure
   compliance with requirements of the HAF award pursuant to 2 CFR 200.332 regarding
   requirements for pass-through entities.

   First, HAF participants must clearly identify to the Subrecipient: (1) that the award is a
   subaward of HAF award funds; (2) any and all compliance requirements for use of HAF
   award funds; and (3) any and all reporting requirements for expenditures of HAF award
   funds.

   Next, HAF participants will need to evaluate each Subrecipient’s risk of noncompliance
   based on a set of common factors. These risk assessments may include factors such as
   prior experience in managing Federal funds, previous audits, personnel, and policies or
   procedures for award execution and oversight. Ongoing monitoring of any given
   Subrecipient should reflect its assessed risk and include monitoring, identification of
   deficiencies, and follow-up to ensure appropriate remediation.
   Accordingly, HAF participants should develop written policies and procedures for
   Subrecipient monitoring and risk assessment and maintain records of all award
   agreements identifying or otherwise documenting Subrecipients’ compliance obligations.

   HAF participants should also note that Subrecipients do not include individuals and
   organizations that received HAF funds as end users to prevent homeowner mortgage
   delinquencies, defaults, foreclosures, loss of utilities or home energy services, and
   displacements. Such individuals and organizations are beneficiaries and not subject to
   audit pursuant to the Single Audit Act and 2 C.F.R. Part 200, Subpart F.


Other Compliance Obligations
HAF participants should ensure they remain in compliance with all Financial Assistance
Agreement Terms and Conditions. These obligations include the following items in addition to
those described above:
1. SAM.gov Requirements. All eligible HAF participants are required to have an active
   registration with the System for Award Management (SAM) (https://www.sam.gov)
   pursuant to the award term at 2 CFR Part 25, Appendix A, which is incorporated by
   reference in the HAF Financial Assistance Agreement.

2. FSRS.gov Reporting Requirements. All HAF participants are required to report
   subaward and executive compensation data pursuant to 2 CFR Part 170, Appendix A
   award term which is incorporated by reference in the HAF Financial Assistance Agreement
   so that it may be made available to the public via www.USASpending.gov. HAF
   participants will use the FSRS.gov reporting tool to report on subawards obligated that are
   in the amount of $30,000 or more. HAF participants must report their executive
   compensation as well as their contract data in SAM.gov.




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                                                 10
3. Recordkeeping Requirements. Generally, a HAF participant must maintain records and
   financial documents for five years after all award funds have been expended or returned
   to Treasury, as outlined in paragraph 5 of the HAF Financial Assistance Agreement.
   Treasury may request transfer of records of long-term value at the end of such period.
   Wherever practicable, such records should be collected, transmitted, and stored in open
   and machine-readable formats.

4. Single Audit Requirements. HAF participants and subrecipients that expended
   $1,000,000 or more in Federal awards during their fiscal year that began on or after
   October 1, 2024 must conduct an audit for that year pursuant to the Single Audit Act and
   its implementing regulation at 2 CFR Part 200, Subpart F regarding audit requirements.
   Similarly, HAF participants and subrecipients that expended $750,000 or more in federal
   award funds during their most recently completed fiscal year that began prior to October
   1, 2024 must conduct an audit for that year pursuant to the Single Audit Act and its
   implementing regulation at 2 CFR Part 200, Subpart F regarding audit requirements.11
   HAF participants and Subrecipients may also refer to the Office of Management and
   Budget (OMB) Compliance Supplements for audits of federal funds and related guidance
   and the Federal Audit Clearinghouse to see examples and single audit submissions.

    Non-Federal entities that expended less than $1,000,000 in Federal awards during their
    fiscal year that began on or after October 1, 2024, or expended less than $750,000 in
    Federal awards during their fiscal year that began before October 1, 2024 are exempt
    from conducting an audit pursuant to the Single Audit Act and 2 CFR Part 200, Subpart F
    for that fiscal year, except as noted in 2 CFR 200.503.

5. Civil Rights Compliance. HAF participants receiving Federal financial assistance from
   the Treasury are required to meet legal requirements relating to nondiscrimination and
   nondiscriminatory use of Federal funds. Those requirements include ensuring that entities
   receiving Federal financial assistance from the Treasury do not deny benefits or services,
   or otherwise discriminate on the basis of race, color, national origin (including limited
   English proficiency), disability, age, sex, religion, or familial status, in accordance with the
   following authorities: Title VI of the Civil Rights Act of 1964 (Title VI) Public Law 88-352,
   42 U.S.C. 2000d-1 et seq., and the Department's implementing regulations, 31 CFR part
   22; Section 504 of the Rehabilitation Act of 1973 (Section 504), Public Law 93-112, as
   amended by Public Law 93-516, 29 U.S.C. 794; Title IX of the Education Amendments of
   1972 (Title IX), 20 U.S.C. 1681 et seq., and the Department's implementing regulations,
   31 CFR part 28; Age Discrimination Act of 1975, Public Law 94-135, 42 U.S.C. 6101 et
   seq., and the Department implementing regulations at 31 CFR part 23; Americans with
   Disabilities Act, 42 U.S.C. 12101 et seq.; and the Fair Housing Act, Title VIII of the Civil
   Rights Act, 42 U.S.C. 3601 et seq. In order to carry out its enforcement responsibilities
   under Title VI of the Civil Rights Act, Treasury will collect and review information from HAF
   participants to ascertain their compliance with the applicable requirements before and after
   providing financial assistance. Treasury’s implementing regulations, 31 CFR part 22, and
   the Department of Justice (DOJ) regulations, Coordination of Non-discrimination in
   Federally Assisted Programs, 28 CFR part 42, provide for the collection of data and
   information from Participants (see 28 CFR 42.406). Treasury may request that non-tribal
   HAF participants submit data for post-award compliance reviews, including information
   such as a narrative describing their Title VI compliance status.




11 For-profit entities that receive HAF subawards are not subject to Single Audit requirements.

However, they are subject to other audits as deemed necessary by authorized governmental entities,
including Treasury, the GAO, the PRAC and the Treasury’s OIG.

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                                                   11
Part 2: Reporting Requirements and Deadlines
There are two types of reporting requirements for the HAF program.

•     Quarterly Report: Report on programs funded, expenditures, program status, and other
      information.
      .
•     Annual Performance Report: Report updating the HAF participants’ HAF Plan on
      programs undertaken with program funding and how the HAF participant plans to ensure
      program outcomes are achieved in an effective, efficient, and equitable manner. This
      report will include status updates on program goals identified by the HAF participant and
      additional mandatory indicators identified by Treasury.

      The Annual Performance Report will be posted on the website of the HAF participant as
      well as provided to Treasury.


Table 1: Reporting requirements by HAF participant type
            Recipient                 Quarterly Report                        Annual Performance Report


    States
                                          By June 10, 2022, and then
                                          45 days after the end of            By November 15, 2022, and
                                          each quarter thereafter.            annually thereafter by mid-
    Tribal Governments with                                                   November.
    Allocation > $5M

    Tribal Governments with               By November 15, 2022, and
    Allocation < $5M & Department of      annually thereafter by mid-
    Hawaiian Home Lands                   November.

The remainder of this document describes these reporting requirements. A user guide will be
provided with additional information on how and where to submit required reports.

Quarterly Report
Executive Summary
HAF participants are required to submit quarterly reports that include data regarding program
expenditures, demographic distribution, civil rights compliance, equity indicators, community
engagement efforts, and programmatic data. To provide public transparency on whether HAF
participants are using practices that promote on-time and on-budget delivery of HAF
assistance, Treasury will seek information from HAF participants on their workforce plans and
practices related to their HAF programs. The requirements that are not applicable to Tribal
Governments and the Department of Hawaiian Home Lands are noted in subsequent sections.

Quarterly Reporting
The following HAF participants are required to submit quarterly reports:
   • States
   • The Department of Hawaiian Home Lands12

12 Please note that the Department of Hawaiian Home Lands will not be required to submit certain

reporting requirements in their templates, which are noted in footnotes throughout the section. DHHL




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    •   Tribal Governments13

The initial Quarterly Report for States and Tribal Governments with allocations greater than
$5 million will cover the Award Date to March 31, 2022 period and must be submitted to
Treasury by June 10, 2022. The subsequent Quarterly Reports will be cumulative and must
be submitted to Treasury within 45 calendar days after the end of each calendar quarter.
Quarterly Reports are due concurrently with applicable Annual Performance Reports. The
table below summarizes the Quarterly Report timelines:

Report    Year     Quarter           Period Covered                                Due Date
   1      2022        1          Award Date – March 31                  Friday, June 10, 2022
   2      2022        2          Award Date – June 30                   Monday, August 15, 2022
   3      2022        3          Award Date – September 30              Monday, November 15, 2022
   4      2022        4          Award Date – December 31               Wednesday, February 15, 2023
   5      2023        1          Award Date – March 31                  Monday, May 15, 2023
   6      2023        2          Award Date – June 30                   Tuesday, August 15, 2023
   7      2023        3          Award Date – September 30              Wednesday, November 15, 2023
   8      2023        4          Award Date – December 31               Thursday, February 15, 2024
   9      2024        1          Award Date – March 31                  Wednesday, May 15, 2024
  10      2024        2          Award Date – June 30                   Thursday, August 15, 2024
  11      2024        3          Award Date – September 30              Friday, November 15, 2024
  12      2024        4          Award Date – December 31               Tuesday, February 18, 2025
  13      2025        1          Award Date – March 31                  Thursday, May 15, 2025
  14      2025        2          Award Date – June 30                   Friday, August 15, 2025
  15      2025        3          Award Date – September 30              Monday, November 17, 2025
  16      2025        4          Award Date – December 31               Tuesday, February 17, 2026
  17      2026        1          Award Date – March 31                  Friday, May 15, 2026
  18      2026        2          Award Date – June 30                   Monday, August 17, 2026
  20      2027      Final        Award Date – September 30              Thursday, January 28, 2027
                   Report

Programmatic Information Requirements

The following programmatic information will be required in Quarterly Reports.


a. Budget- HAF participants will be required to report Obligations and Expenditures relative to
   their HAF Plan from Award Date to Calendar Quarter end date. The information provided
   in this section of the report will relate to their HAF Plan Budget.

b. Homeowner Applications- HAF participants will be required to report on metrics around
   received and approved unique Homeowner applications. More specifically, HAF




will be required to submit its first quarterly and annual reports starting with Calendar Quarter 3 of 2022
with submissions due by November 15, 2022.
13 Please note that Tribal Governments will not be required to submit certain reporting requirements in

their templates, which are noted in the footnotes of this section. Tribal Governments with allocations
greater than $5 million will need to submit quarterly reports starting in Calendar Quarter 1 of 2022 with
submissions due by June 10, 2022. Tribal Governments with allocations less than $5 million will
submit annual reports (same content as quarterly reports for Tribal Governments with allocations
greater than $5 million) starting in Calendar Quarter 3 of 2022 with submissions due by November 15,
2022.

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  participants will be asked to report on the following metrics regarding applications with each
  question disaggregated by the categories such as race14, ethnicity, gender, and income
  AMI%:

  •   Number of unique Homeowners that have submitted a draft or completed HAF
      application;
  •   Number of unique Homeowners that have submitted a completed HAF application;15
  •   Number of unique Homeowners that submitted a draft or completed HAF application
      that was then subsequently withdrawn by the Homeowner;
  •   Number of unique Homeowners whose application was approved;
  •   Number of unique Homeowners whose application was denied;
             o Disaggregation of denial separated by reason category. The categories are
                 as follows: income eligibility, lack of COVID related financial hardship,
                 property not the primary residence, principal balance exceeded conforming
                 loan limit, application not completed within program timeframe, servicers not
                 participating, delinquency amount exceeds program cap, and other to
                 include a narrative.
             o Number of unique Homeowners who applied for assistance that had
                 previously received HAF assistance; and, E.g., a homeowner who receives
                 HAF assistance and then submits a subsequent application for HAF
                 assistance of any kind.
  •   Number of unique Homeowners that received assistance on more than one application.
             o E.g., a homeowner who receives assistance, and then applies and receives
                 HAF assistance of any kind on a subsequent application.

c. Targeting- HAF participants will be required to report on targeting metrics, including the
   following:

  •   The number of unique Homeowners that received HAF assistance;
  •   The number of unique Homeowners that received HAF assistance and were at or below
      100% Area Median Income (AMI) or United States Median Income (USMI) (whichever
      is greater/the HAF participant opted for in order to administer assistance); and,
  •   The number of unique Homeowners that received HAF assistance and were classified
      as a “Socially Disadvantaged Individual” (SDI).16

  HAF participants will be asked to disaggregate these metrics by the categories noted under
  the Disaggregated Information requirement below.17

d. Delinquencies- HAF participants will be required to report on the number of Delinquencies
   resolved using HAF assistance. For the purposes of this guidance a resolved Delinquency
   means any resolution to the delinquency excluding foreclosure. Delinquencies can be
   resolved through two forms of HAF assistance: Monetary or Non-Monetary. Delinquencies
   resolved through Monetary HAF assistance includes direct support to homeowners, such
   as mortgage payment assistance, to resolve a Delinquency. Delinquencies resolved
   through Non-Monetary HAF assistance includes indirect support (e.g., housing counseling,

14 For disaggregation purposes, where a homeowner has indicated more than one race to a HAF

participant, the participant may count the homeowner towards each race that the homeowner has
indicated.
15 This figure may be the same as the “Number of unique Homeowners that submitted a draft or

completed HAF application” for certain recipients.
16 Tribal Governments and the Department of Hawaiian Home Lands will not be asked to report on the

number of unique Homeowners that received HAF assistance and were classified as a “Socially
Disadvantaged Individual.”
17 Tribal Governments and the Department of Hawaiian Home Lands will not be asked to

disaggregate targeting data.



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                                                  14
   or referral to legal services) to resolve a Delinquency. The types of Non-Monetary
   Assistance provided as an example above do not represent an exhaustive list of Non-
   Monetary Assistance activities. HAF participants are expected to track the number of
   Delinquencies resolved as a result of HAF assistance and its category (Monetary or Non-
   Monetary) at the participant-level and program-level.

e. Reimbursement- HAF participants will provide information on any reimbursement
   expense(s) and the associated program design element that the reimbursement expense(s)
   is/are linked to.

f. Program(s) Information- HAF participants will provide information on all HAF programs.
   Programs are new or existing eligible government services or investments funded in whole
   or in part by HAF funding. For each program, the HAF participant will be required to enter
   the following information:

    •   Program Name;
    •   Identification Number;
    •   Program Start Date;
    •   Program Description;
    •   Program Design Elements Covered by the Program (selected by the HAF participant);
    •   Total Obligations Cumulative to Calendar Quarter end date;
    •   Total Expenditures Cumulative to Calendar Quarter end date;
    •   Number of Homeowners Assisted Cumulative to Calendar Quarter end date;
    •   Number of SDIs Assisted Cumulative to Calendar Quarter end date18;
    •   Number of Delinquencies Resolved with Non-Monetary and Monetary HAF Assistance
        Cumulative to Calendar Quarter end date;
    •   Program Income Earned Cumulative to Calendar Quarter end date; and,
    •   Program Income Expended Cumulative to Calendar Quarter end date.

g. Expenditures- HAF participants are required to report the HAF assistance expended or
   spent by the HAF participant. HAF participants will be asked to report expenditures on a
   cumulative basis at the following levels: the participant-level, program-level, and program
   design element-level. At the participant-level, HAF participants will be asked to
   disaggregate expenditures or amounts expended by the categories noted under the
   Disaggregated Information requirement below.19

    •   The information provided in this section will relate to the HAF Plan Budget
        Expenditures broken out by Program Design Element.

h. Obligations- HAF participants are required to report the HAF assistance obligated. HAF
   participants will be asked to report obligations on a cumulative basis at the participant-level,
   program-level, and program design element-level. HAF participants will be asked to
   disaggregate participant-level obligations by the categories noted under the Disaggregated
   Information requirement below.20

    •   The information provided in this section will relate to the HAF Plan Budget Obligations
        broken out by Program Design Element.


18 Please note, Tribal Governments and the Department of Hawaiian Home Lands will not be required

to report on Program SDIs assisted.
19 Please note, Tribal Governments and the Department of Hawaiian Home Lands will not be required

to disaggregate information related to Expenditures.
20 Please note, Tribal Governments and the Department of Hawaiian Home Lands will not be required

to disaggregate information related to Obligations.



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                                                   15
i.   Program Design Elements Covered- HAF participants will report on each of their HAF term
     sheets identified programs and their respective program design elements. HAF participants
     that provide funding for housing counseling and legal services will also report in this section.
     HAF participants will create a new line item for each program design element and tie the
     program design element to a specific program. Please reference Appendix 3 for Program
     Design Element categories and descriptions. HAF participants will be expected to report
     the following for each specific program design element within a program:

     •   Total Obligations Cumulative to Calendar Quarter end date;
     •   Total Expenditures Cumulative to Calendar Quarter end date;
     •   Number of Homeowners Assisted Cumulative to Calendar Quarter end date; and,
     •   Number of SDIs Assisted Cumulative to Calendar Quarter end date.21

j.   Disaggregated Information- HAF participants are expected to know how their HAF
     assistance has impacted different demographic groups in addition to other categories. This
     information will help determine equity indicators and confirm that HAF participants are
     reaching the appropriate population with HAF assistance. HAF participants will report on
     the following disaggregated categories at the participant-level for the number of unique
     Homeowners that received HAF assistance, the number of unique Homeowners classified
     as SDIs that received HAF assistance, the amount of HAF assistance obligated, and the
     amount of HAF assistance expended:

     •   Race22
     •   Ethnicity
     •   Gender
     •   Area Median Income Level
     •   Socially Disadvantaged
     •   Mortgages
     •   Housing Type
     •   Zip Code

     More information on the distinct breakdown of these disaggregated categories and the sub-
     levels can be found in Appendix 1 and Appendix 2.

 Compliance Information Requirements

 The following compliance information will be required in Quarterly Reports:

k. Socially Disadvantaged Individual Definition – HAF participants will need to confirm the
   definition they used for a “Socially Disadvantaged Individual” (SDI) during the report
   quarter. The SDI definition will be pulled from the HAF participant’s HAF plan. If a HAF
   participant has changed or needs to adjust their definition of an SDI, they will select ‘deny’
   in the form and write their new SDI definition in the text box provided.23

The below questions are Compliance Information regarding Self-Disclosure of Improperly
Funded HAF Assistance



 21 Please note, Tribal Governments and the Department of Hawaiian Home Lands will not be required

 to report on Program Design Element SDIs assisted.
 22 Disaggregated Race data may include individuals who reported more than one race. Counting of a

 unique Homeowner under more than one racial category is allowed in this data element.
 23Tribal Governments and the Department of Hawaiian Home Lands will not be asked to confirm their

 “Socially Disadvantaged Individual” Definition



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Note: Using the questions below, determine if HAF assistance was improperly paid.
Additionally, please provide detail on how it was identified and what remedial measures
were/are being taken to address the issue and ensure it doesn’t happen again.

l.   Maximum Conforming Loan Limit – HAF participants will need to report if they have used
     HAF assistance to assist homeowners with loans above the maximum conforming loan limit
     as defined in the HAF statute, 15 U.S.C. 9058d(b)(1). If a HAF participant answers in the
     affirmative, they will need to provide an explanation about why it assisted homeowners with
     loans above the maximum conforming loan limit.

m. Written Attestations – HAF participants will need to report if they required homeowners to
   provide attestations about financial hardship prior to disbursing HAF assistance. If the HAF
   participant answers in the negative, they will need to provide an explanation about why they
   did not require or receive attestations from homeowners.

n. Annual Income – In determining income for each homeowner applying for HAF
   assistance, HAF participants will need to report if they used HUD’s definition of “annual
   income” in 24 CFR 5.609 (https://www.govinfo.gov/content/pkg/CFR-2021-title24-
   vol1/pdf/CFR-2021-title24-vol1.pdf) or adjusted gross income as defined for purposes of
   reporting on IRS Form 1040 series as mentioned in the HAF guidance or other proxies
   approved in their HAF Plan. If the HAF participant answers in the negative, it will need to
   provide an explanation about why they did not use HUD’s definition of “annual income” in
   24 CFR 5.609 or adjusted gross income as defined for purposes of reporting on IRS Form
   1040 series as mentioned in the HAF guidance.

o. Targeting AMI/USMI Dollar Amount – HAF participants will need to report the dollar amount
   of monetary HAF assistance Obligated and Expended to homeowners with incomes less
   than the greater of 100% AMI or US Median Income.

p. Targeting AMI/USMI Assistance – HAF participants will need to report if they Expended at
   least 60% of monetary HAF assistance to homeowners with incomes less than the greater
   of 100% Area Median Income or US Median Income. If the HAF participant answers in the
   negative, they will need to provide an explanation about why they did not Expend at least
   60% of HAF assistance to homeowners with that income threshold.

q. Certifications – HAF participants will need to read, review, and sign all relevant certifications
   in the Quarterly Report on Treasury’s reporting portal. By signing the certifications, the
   authorized representative for the HAF participant confirms that the HAF participant is in
   compliance with all the requirements of the HAF statute, HAF Guidance, and HAF Financial
   Assistance Agreement and that the HAF participant has answered all questions truthfully.
 Required Components of Standard Financial Reporting (SF-425)

 All HAF participants must submit the corresponding contents of the Federal Financial Report,
 Standard Form 425 (SF-425), on a quarterly basis. Treasury uses the financial data to
 compare the rate of the participant’s actual expenditures against performance data to verify
 that expenditure amounts align with program activities.

 Annual Performance Report
 Executive Summary
 HAF participants will be asked to provide a high-level overview of their intended and actual
 uses of funding including, but not limited to the following: the HAF participant’s plan for use of
 funds to promote a response to the pandemic and economic recovery, key outcome goals,




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progress to date on those outcomes, and any noteworthy challenges or opportunities identified
during the reporting period.

Annual Performance Reporting
The following HAF participants are required to submit Annual Performance Reports:
   • States
   • The Department of Hawaiian Home Lands
   • Tribal Governments

HAF participants are required to submit an Annual Performance Report on an annual basis
and demonstrate the impact of the HAF-financed programs. Reports should include data
related to program outputs and outcomes against the stated objectives of the HAF participant’s
HAF Grant Plan.

       Report             Period Covered                                Due Date
         1        Award Date – September 30, 2022              Tuesday, November 15, 2022
         2        October 1, 2022 – September 30,              Wednesday, November 15,
                               2023                            2023
           3      October 1, 2023 – September 30,              Friday, November 15, 2024
                               2024
           4      October 1, 2024 – September 30,              Monday, November 17, 2025
                               2025
        Final     Award Date – September 30, 2026              Thursday, January 28, 2027
       Report

Each Annual Performance Report must be posted on the public-facing website of the HAF
participant on or by the same date the HAF participant submits the report to Treasury.24 The
Annual Performance Report will include, at a minimum, the following information:

Community Engagement
HAF participants will provide an update on how the HAF participant planned or current use of
funds incorporates written, oral, and other forms of input that capture diverse feedback from
constituents, community-based organizations, and the communities themselves. Where
relevant, this description must include how funds will build the capacity of community
organizations to serve people with significant barriers to services, including people of color,
people with low incomes, limited English proficient populations, and other traditionally
underserved groups.
Performance Goals
HAF participants initially submitted performance goals on the use of HAF award funds in their
approved HAF Plan. Each one of the performance goals should have identified how the HAF
participant will address homeowner needs and should have been disaggregated by key
characteristics such as mortgage type, racial and ethnic demographics, and/or geographic
areas, as appropriate. HAF participants will be required to provide a status update and
quantitative measures, if applicable, on each of their initial performance goals set forth in their
HAF Plan. Please note, HAF participants will not have the ability to alter their original
performance goals noted in their HAF Plan nor add additional performance goals in the Annual
Report.




24 Tribal Governments will not be required to post their Annual Performance Report to a public-facing

website.



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Methods for Targeting and HAF Funding
HAF participants were asked in their original HAF Plan to describe how the HAF participant
will effectively target HAF award funds to (1) homeowners with incomes equal to or less than
100% of the area median income or equal to or less than 100% of the median income for the
United States, whichever is greater; and (2) socially disadvantaged individuals. The
description included the HAF participant’s targeting strategies. HAF participants will be
required to provide an update on their targeting methods and if they have appropriately
executed targeting methods according to their original HAF Plan.


Best Practices and Coordination with Other HAF participants
HAF participants will be required to describe any relevant coordination with federal agencies,
including Federal Housing Administration (FHA), Veterans Affairs (VA), and U.S. Department
of Agriculture (USDA), as well as with state or local agencies that hold mortgage portfolios
that have covenants or targeting requirements that match the HAF participants’ HAF
targeting strategies and goals.
Budget by Program Design Element (if adjusting)
HAF participants will need to validate the current program design element budget expended
to date against their original projected budget amounts. The Annual Report will have the
Grantee Plan budget amounts prepopulated for each program design element. HAF
participants are expected to adhere to these budget amounts unless they have submitted a
request for a revision to their HAF Plan and the request has been formally accepted by
Treasury.

Civil Rights Compliance
Treasury may request information on the HAF participant’s compliance with Title VI of the Civil
Rights Act of 1964 on an annual basis. This information may include a narrative describing
the HAF participant’s compliance with Title VI, along with other questions and assurances,
including actions taken and systems established to ensure that members of all relevant
protected classes have full access to the HAF participant’s program, including people with
disabilities and others, and data needed to determine compliance with applicable civil rights
statutes. This collection does not apply to Tribal Governments.




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Appendix 1 – Race, Ethnicity and Sex Categories

The following list includes of race, ethnicity, and sex categories for HAF participant data
collection and reporting.


Race
       American Indian or Alaska Native
       Asian
              Indian
              Chinese
              Filipino
              Japanese
              Korean
              Vietnamese
              Asian (Other)
              Sub-Category Not Collected
       Black or African American
       Native Hawaiian or Other Pacific Islander
              Guamanian or Chamorro
              Native Hawaiian
              Samoan
              Pacific Islander (Other)
              Sub-Category Not Collected
       White
       Declined to Answer
       Data Not Collected


Ethnicity
       Hispanic or Latino/a
       Not Hispanic or Latino/a
       Declined to Answer
       Data Not Collected


Sex
       Female
       Male
       Declined to Answer
       Data Not Collected




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Appendix 2 – Targeting Categories
The following are key targeting categories for HAF participant data collection and reporting.

Income: Area Median Income
       Below or equal to 50%
       Greater than 50% and less than or equal 80%
       Greater than 80% and less than or equal to 100%
       Greater than 100% and less than or equal to 150%
       Greater than 150%
       Data Not Collected

Socially Disadvantaged
       Racial or Ethnic Prejudice – member of a group that has been subjected to racial or
       ethnic prejudice or cultural bias within American society.
       Majority-Minority Census Tract – resident of a majority-minority Census tract.
       Limited English Proficiency – individual with limited English proficiency.
       Resident US Territory, Indian Reservation, or Department of Hawaiian Home Lands –
       resident of a U.S. territory, Indian reservation, or Department of Hawaiian Home
       Lands.
       Persistent Poverty County – individual who lives in a persistent-poverty county,
       meaning any county that has had 20% or more of its population living in poverty over
       the past 30 years as measured by the three most recent decennial censuses.
       Other – individual in accordance with a process developed by a HAF participant for
       determining whether a homeowner is a socially disadvantaged individual in
       accordance with applicable law, which may reasonably rely on self-attestations.
       N/A – individual was not classified as Socially Disadvantaged.
Mortgages
       Federal Housing Administration (FHA)
       Department of Veterans Affairs (VA)
       U.S. Department of Agriculture (USDA)
       Government Sponsored Enterprise (GSE)
       Private-label Securities
       Reverse Mortgages
       Portfolio Loan
       Land Contracts
       N/A
       Data Not Collected

Housing Type
      Single Family Home
      Condominium
      Manufactured Housing


                                   Homeowner Assistance Fund:
                   Guidance on Participant Compliance and Reporting Responsibilities

                                                  20
      Other
      Data Not Collected

Zip Code
      HAF participants will be expected to collect number of Homeowners and program
      funds Obligated and Expended at the zip code level.




                                Homeowner Assistance Fund:
                Guidance on Participant Compliance and Reporting Responsibilities

                                               21
Appendix 3 – Program Design Element Categories

The following is a list of program design elements for HAF participant data collection and
reporting.

Program Design Elements
       Mortgage Payment Assistance – mortgage payment assistance. Lot-rent on a
       Manufactured Home is eligible as a Qualified Expense under this category.
       Financial Assistance – 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. Lot-rent on a Manufactured Home is eligible as a Qualified
       Expense under this category.
       Mortgage Principal Reduction – mortgage principal reduction, including with respect
       to a second mortgage provided by a nonprofit or government entity.
       Facilitating Interest Rate – facilitating mortgage interest rate reductions.
       Payment Assistance Utilities – payment assistance for homeowner’s utilities,
       including electric, gas, home energy (including firewood and home heating oil), water,
       and wastewater.
       Payment Assistance Internet – payment assistance for homeowner’s internet service,
       including broadband internet access service, as defined in 47 CFR 8.1(b).
       Payment Assistance Insurance – payment assistance for homeowner’s insurance,
       flood insurance, and mortgage insurance.
       Payment Assistance Fees – payment assistance for 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.
       Payment Assistance Loans – payment assistance for down payment assistance
       loans provided by nonprofit or government entities.
       Payment Assistance Taxes – payment assistance for delinquent property taxes to
       prevent homeowner tax foreclosures.
       Measures Preventing Displacement – measures to prevent homeowner
       displacement, such as home repairs to maintain the habitability of a home, including
       the reasonable addition of habitable space to alleviate overcrowding, or assistance to
       enable households to receive clear title to their properties. Lot-rent on a
       Manufactured Home is eligible as a Qualified Expense under this category.
       Counseling or Education – counseling or educational efforts by housing counseling
       agencies approved by HUD or a tribal government targeted to households eligible to
       be served with funding from the HAF related to foreclosure prevention or
       displacement.
       Legal Services – legal services targeted to households eligible to be served with
       funding from the HAF related to foreclosure prevention or displacement.



                                  Homeowner Assistance Fund:
                  Guidance on Participant Compliance and Reporting Responsibilities

                                                 22


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