Treasury, HAF Standard Closeout Checklist
Summary
Treasury's "Standard Closeout" checklist for HAF recipients that have not submitted their Final Reports by September 30, 2026, the end of the period of performance. From that date recipients have 120 calendar days, the "liquidation period," to submit their two Final Reports through Treasury's Portal; they are due to Treasury on January 28, 2027. Part A covers steps before September 30, 2026: recipients and subrecipients may no longer obligate HAF award funds after that date, so all funds should be obligated by then. Later items ask recipients to clear outstanding information document requests, Management Decision Letters and notices of noncompliance, which can delay closeout. Records retention and audit requirements continue after the award is closed.
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“Treasury, HAF Standard Closeout Checklist.”
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Standard Closeout Checklist for HAF Awards
“Standard Closeout” Checklist for HAF Awards
For HAF recipients that have not submitted their HAF Final Report by September 30, 2026
Use this checklist to support successful submission of
your two Final Reports to closeout your HAF award. Key Dates to Remember:
This checklist does not necessarily reflect all closeout
preparation activities in which a HAF Recipient may • September 30, 2026: End of the Period
of Performance for HAF awards
engage.
• December 29, 2026: Subrecipient's final
Recipients that answer “no” to any of the applicable
financial and performance reports are
questions in Part A or Part B, should consider due to HAF Recipient
strategies to ensure the timely and successful
closeout of their HAF award. • January 28, 2027: HAF recipients’ Final
Reports are due to Treasury
The end date of the period of performance for HAF
awards on September 30, 2026 marks the beginning of
the “standard” closeout period for all recipients of HAF awards that did not initiate early award
closeout. You, as the HAF Recipient, will have 120 calendar days after September 30, 2026 (the
“liquidation period”) to submit the two Final Reports to Treasury via Treasury’s Portal. Please remember
that HAF recipients will still remain subject to records retention and audit requirements after award
closeout (see HAF Closeout Resource for more details).
PART A: Prior to September 30, 2026
Preparing for the end of the Period of Performance for HAF Awards:
Have you and/or your subrecipient(s) obligated all of your HAF award funds? HAF recipients
and subrecipients may no longer obligate HAF award funds after September 30, 2026. It is
critical to ensure that HAF recipients and their subrecipients have properly obligated HAF award
funds for all eligible HAF expenses by September 30, 2026 – including the eligible administrative
expenditures related to award closeout for closeout activities that will be completed after
September 30, 2026.
Administrative activities
Have you obligated funds for the administrative activities that will allow your subrecipients to
complete their HAF reporting activities by December 29, 2026 and to facilitate your (the HAF
recipients’) submission of your HAF Final Reports by January 28, 2027?
Note: Remember that there is a limit of 15% of the total HAF award amount for
administrative costs (i.e., the recipient and its subrecipients administrative costs
combined must be at the 15% limit). See “Part B” below for more detail about potential
allowable activities during the liquidation period for which you may wish to obligate
funds for administrative expenses by September 30, 2026.
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Standard Closeout Checklist for HAF Awards
Have you collected or will you collect returned and/or recovered funds such as improper
payments or program income associated with any loan repayments or other financial
arrangements funded by your HAF award prior to September 30, 2026?
Note: 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.1 Please
see page 13 in the HAF Closeout Resource for more detailed information.
Are you prepared to return excess interest earned on the HAF award funds appropriately?
Prior to submitting the Final Reports, any earned interest per year that is above $500 must be
remitted to the DHHS PMS System. Once a recipient submits the Final Reports, any unexpended
earned interest remaining must be returned to Treasury along with any unexpended HAF award
funds.
Note: 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. Please see page 12 in
the HAF Closeout Resource for more detailed information.
Does your 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 submitting their Final Reports.
Note: There are three reasons HAF participant must seek prior approval from Treasury to
reallocate funding from a program as described in the approved budget:
• the aggregate reallocations from any qualified expense category equals or
exceeds 10% of the amount allocated to that qualified expense category in the
HAF plan approved by Treasury;
• the HAF participant is proposing to allocate funding to a new qualified expense
category or is creating a new program or terminating a previously approved
program; or
• the reallocation redirects 1% or more of the participant’s total HAF allocation
from program costs to administrative costs. Please see page 11 in the HAF
Guidance for more detailed information.
Program Activities
Are you on track to expend all HAF award funds that are obligated for program activities such
as mortgage payment assistance or reinstatement, utilities, payment assistance for property
taxes, measures to prevent homeowner displacement, and housing counseling by September
30, 2026?
o HAF recipients must obligate HAF award funds for all HAF eligible activities including
administrative expenses for closeout activities by September 30, 2026. Those
obligations must be paid in full within 120 calendar days after September 30, 2026 to
1 Except for program income. Recipients are not required to return program income recovered after September 30, 2026.
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Standard Closeout Checklist for HAF Awards
facilitate the inclusion of those expenditures in the Final Reports for timely submission
to Treasury by January 28, 2027.
o HAF award funds obligated for HAF eligible activities by September 30, 2026 but are not
paid in full by January 28, 2027 must be returned to Treasury through the closeout
process.
o Allowable program activities after September 30, 2026 include payment processing for
approved HAF applicants. These obligations must be paid in full by January 28, 2027.
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.
Are you on track to complete activities related to mortgage payment assistance or
reinstatement, utilities, payment assistance for property taxes, measures to prevent
homeowner displacement, and housing counseling by September 30, 2026?
o HAF award funds cannot cover any financial assistance for housing related costs that will
cover any period after September 30, 2026.
For example: If a recipient has paid funds to cover homeowners’ insurance, those funds
can only cover homeowners’ insurance for the months prior to (or that end on)
September 30, 2026.
For example: if a recipient processes payments of HAF award funds on January 1, 2026
to cover a 12-month homeowners insurance policy, the recipient may cover the
insurance costs for January through September 2026 with HAF award funds. The months
of October, November and December 2026 are ineligible expenditures and can’t be
covered with the HAF award because the activity (insurance coverage for October
through December 2026) is for a period after the end date of the period of performance,
even though the funds were expended for homeowners’ insurance prior to September
30, 2026.
Are you on track to complete activities associated with HAF award payments for measures to
prevent homeowner displacement (including project scope, operations, acquisition of
materials, and completion of repairs) by September 30, 2026?
Note: HAF recipients should be prepared to affirm in their Final Reports that all the
activities described as part of the measures to prevent homeowner displacement are
complete. HAF award funds cannot be used to fund project activities that occur after
September 30, 2026. For example, for a window repair, a HAF Recipient may use HAF
award funds for windows that will be completely installed by September 30, 2026, but
not after that date.
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Standard Closeout Checklist for HAF Awards
PART B: Liquidation Period (September 30, 2026- January 28, 2027)
Administrative activities to support successful HAF Award closeout
See pages 5 and 6 of the HAF Closeout Resource for permissible and prohibited expenditures after
September 30, 2026 with the HAF Award.
Have you and/or your subrecipient(s) processed all final payments for mortgage payment
assistance or reinstatement, utilities, payment assistance for property taxes, measures to
prevent homeowner displacement and housing counseling, etc.?
Have you and/or your subrecipients completed all administrative activities and/or liquidated all
HAF award obligations for administrative expenses (staff salaries, subawards, contracts, etc.)?
Subrecipient administrative activities must be completed by December 29, 2026.
Administrative activities may include those to support award closeout such as:
o Review and reconciliation of general ledger, accounting, reporting, and bank
reconciliation.
o Verification that all HAF data submitted in the HAF Final Reports complies with the
applicable requirements of the HAF Award Terms, HAF Reporting Guidance, and the
HAF Final Reports User Guide including that:
Cumulative program and financial data are complete and accurate, as required
by the Quarterly and Annual Reporting requirements.
Information about equipment and supplies and tangible real property, as
applicable, is compiled consistently with the requirements set forth in the SF-
428 and SF-428S forms, see the HAF Closeout Resource.
o Review of program policies, procedures, and controls to ensure eligible use of award
funds.
Note: This may involve follow-up with end-beneficiaries (e.g., servicers, utility
companies, homeowners, etc.) to reconcile documentation, as needed. HAF award funds
obligated by September 30, 2026 for administrative costs related to award closeout
cannot fund any administrative activities that occur after the HAF recipient submits both
Final Reports to Treasury.
o Preparation to complete the SF-428 and SF-428S forms if HAF award funds were used to
acquire supplies and/or sold its residual inventory of unused supplies with a total
aggregate fair market value above $10,000 or acquired equipment with a per unit
acquisition cost greater than $10,000.
o Ensuring timely completion of a single audit or program-specific audit, as applicable,
and submission of audit report to the Federal Audit Clearinghouse if the HAF recipient
has expended $1,000,000 or more in federal awards during its most recently completed
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Standard Closeout Checklist for HAF Awards
fiscal year. See 2 CFR 200.507(c) and 2 CFR 200.512.
o Preparation for post-closeout activities:
Designate staff contacts for Treasury to communicate with during Treasury’s
review of the Final Reports, including at least one active Account Administrator
and Authorized Representative. See Designating Points of Contact for HAF
Account Administrators.
Register staff contacts in Treasury’s Portal for any continuing accounting
responsibilities (such as tracking returned funds, verifying the Pre-Debt Notice
sent by Treasury at the end of Treasury’s review of your Final Reports for HAF
award closeout).
Establish processes and a resource plan to support ongoing data security
measures and protection of personally identifiable information.
Establish processes and a resource plan to support the 5-year documentation
retention requirements, in alignment with the HAF Closeout Resource. (See
page 8.)
o Preparation of an administrative plan for the post-closeout processing of returned
funds. For instance:
Establishing a process for routing returned payments.
Establishing responsible staff to process returned payments.
Have you resolved any outstanding compliance items that might affect the timely submission
of your Final Reports? If no: HAF Recipients must ensure that they are expediently reviewing
and properly addressing any outstanding information document requests (IDRs), Management
Decision Letters (MDLs), or notices of noncompliance to facilitate timely submission of their
Final Reports to Treasury by the deadline. Outstanding noncompliance issues can delay the
award closeout process. Contact Treasury with any concerns via email at HAF@Treasury.gov.
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