The Homeowner Assistance Fund in the American Rescue Plan Act: In Brief

The Homeowner Assistance Fund in the American Rescue Plan Act: In Brief

The Homeowner Assistance Fund in the
American Rescue Plan Act: In Brief
Updated September 20, 2021
Congressional Research Service
https://crsreports.congress.gov
R46830

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The Homeowner Assistance Fund in the American Rescue Plan Act: In Brief

Contents
Introduction ................................................................................................................... 1
Background.................................................................................................................... 1
Funding Allocations ........................................................................................................ 2
State and Territory Allocations..................................................................................... 3
Tribal Al ocations ...................................................................................................... 5
Program Parameters ........................................................................................................ 6
Eligible Uses of Funds ............................................................................................... 6
Eligible Homeowners ................................................................................................. 7
Targeting of Funds ..................................................................................................... 7
Funding Availability and Planning Requirements............................................................ 8
Reporting Requirements ............................................................................................. 9
Outstanding Questions ..................................................................................................... 9
How will participating entities structure their programs?.................................................. 9
How effective will the HAF be?................................................................................. 11

Tables
Table 1. HAF State Al ocations ......................................................................................... 3
Table 2. HAF Territory Al ocations .................................................................................... 5

Contacts
Author Information ....................................................................................................... 12

The Homeowner Assistance Fund in the American Rescue Plan Act: In Brief

Introduction
The American Rescue Plan Act of 2021 (ARPA, P.L. 117-2) included $9.961 bil ion for a new
Homeowner Assistance Fund (HAF) administered by the Treasury Department.1 Through the
program, Treasury al ocates funds via formula to eligible entities, which in turn can use the funds
to assist eligible homeowners with mortgage payments or certain other related housing expenses.
This report provides an overview of the HAF based on ARPA and program guidance released by
Treasury as of the cover date of this report. (Treasury released initial program guidance on April
14, 20212 and updated that guidance on August 2, 2021.3) It includes brief background on the
creation of the HAF, information on funding al ocations, a description of key program
parameters, and a discussion of certain outstanding questions.
Background
The COVID-19 pandemic and its resulting economic ramifications have made it difficult for
many households to afford their housing payments.4 Since the beginning of the pandemic,
Congress and the Trump and Biden Administrations have taken several steps to assist both renters
and homeowners who are having difficulty remaining current on housing payments. Assistance
for renters has included funding for an emergency rental assistance program as wel as temporary
federal moratoriums on evictions under certain circumstances.5 Assistance for homeowners has
included mortgage forbearance6 and a temporary foreclosure moratorium for federal y backed

1 Program information is available on T reasury’s Homeowner Assistance Fund website at https://home.treasury.gov/
policy-issues/coronavirus/assistance-for-state-local-and-tribal-governments/homeowner-assistance-fund.
2 T he original April 14, 2021, T reasury guidance is available at https://web.archive.org/web/20210415164653/https://
home.treasury.gov/system/files/136/HAF-Guidance.pdf.
3 As of the cover date of this report, the August 2, 2021, T reasury guidance is available at https://home.treasury.gov/
system/files/136/HAF-Guidance.pdf.
4 See, for example, Consumer Financial Protection Bureau, Housing insecurity and the COVID-19 Pandemic, March
2021, https://files.consumerfinance.gov/f/documents/cfpb_Housing_insecurity_and_the_COVID-19_pandemic.pdf.
5 For more information on emergency rental assistance funding, see CRS Report R46688, Pandemic Relief: The
Em ergency Rental Assistance Program . For more information on the eviction moratoriums, see CRS Insight IN11516,
Federal Eviction Moratorium s in Response to the COVID-19 Pandem ic; and CRS Insight IN11673, The CDC’s
Federal Eviction Moratorium .
6 Forbearance refers to a period during which a borrower is allowed to make reduced mortgage payments or suspend
payments altogether. Forbearance is not debt forgiveness; the borrower must ultimately make the missed mortgage
payments after the forbearance period ends, though there may be different options for how and when to do so. For more
information on mortgage forbearance for federally backed mortgages in response to the pandemic, see the Consumer
Financial Protection Bureau’s website at https://www.consumerfinance.gov/coronavirus/mortgage-and-housing-
assistance/help-for-homeowners/learn-about -forbearance/.
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The Homeowner Assistance Fund in the American Rescue Plan Act: In Brief

mortgage loans.7 The foreclosure moratoriums for federal y backed mortgages expired after July
31, 2021,8 and the federal eviction moratorium is no longer being enforced.9
Although many homeowners have benefited from mortgage forbearance or foreclosure
moratoriums, there have been concerns about homeowners’ ability to resume mortgage payments
or repay past due amounts10 after these protections end.11 In addition, for homeowners whose
mortgages are not federal y backed, mortgage servicers are general y not required to offer
forbearance or other specific assistance options (although many may do so). Some homeowners
may also face foreclosure or displacement due to an inability to pay other housing-related costs
(e.g., association fees or property taxes). Given these concerns, a variety of housing, consumer,
and industry organizations had urged Congress to provide additional assistance for homeowners
having difficulty meeting their housing costs due to financial hardships experienced during the
pandemic.12
Section 3206 of ARPA established the $9.961 bil ion HAF at the Treasury Department. Under it,
Treasury al ocates funds via formula to states, territories, tribes, and the Department of Hawai an
Homelands (DHHL). These entities, in turn, can use the funds to assist eligible homeowners with
certain qualified expenses related to their housing costs in order to prevent mortgage delinquency,
default, foreclosure, displacement, or loss of utilities or home energy services.
Funding Allocations
States, territories, federal y recognized tribes, and DHHL are al eligible to receive funding from
the HAF. Puerto Rico and the District of Columbia are considered states for the purposes of the
HAF. As described below, there are some differences in how funds are al ocated between these

7 For the purposes of these provisions, federally backed mortgages are defined as mortgages made, insured, or
guaranteed by the Department of Housing and Urban Development (including the Federal Housing Administration),
Department of Veterans Affairs, or Department of Agriculture; or mortgages purchased or securitized by Fannie Mae
or Freddie Mac. For more information on assistance for homeowners during the pandemic, see CRS Insight IN11334,
Mortgage Provisions in the Coronavirus Aid, Relief, and Econo m ic Security (CARES) Act; and “ T he COVID-19
Pandemic and Housing” in CRS Report R45710, Housing Issues in the 116th Congress.
8 Per the relevant agencies’ administrative guidance, moratoriums on foreclosures on federally backed mortgage loans
expired after July 31, 2021, following several administrative extensions.
9 For more information on the status of the federal eviction morat orium implemented by the Centers for Disease
Control and Prevention (CDC), see CRS Insight IN11673, The CDC’s Federal Eviction Moratorium ; and CRS Legal
Sidebar LSB10638, Suprem e Court Blocks Enforcem ent of the CDC’s Eviction Moratorium .
10 T he federal agencies that back mortgages and Fannie Mae and Freddie Mac have all stated that borrowers will not be
required to repay past -due amounts in a lump sum at the end of the forbearance period if they are not able to do so.
T hese entities have other options that homeowners may qualify for to repay past -due amounts, although the specifics
vary based on the entity involved. See “ CARES Act Forbearance Fact Sheet for Mortgagees and Servicers of FHA,
VA, or USDA Loans,” https://www.hud.gov/sites/dfiles/SFH/doc uments/IACOVID19FB_FactSheetServicers.pdf;
Federal Housing Finance Agency, “ ‘No Lump Sum Required at the End of Forbearance’ says FHFA’s Calabria,” press
release, April 27, 2020, https://www.fhfa.gov/Media/PublicAffairs/Pages/No-Lump-Sum-Required-at-the-End-of-
Forbearance-says-FHFAs-Calabria.aspx; and the Consumer Financial Protection Bureau’s website at
https://www.consumerfinance.gov/coronavirus/mortgage-and-housing-assistance/help-for-homeowners/repay-
forbearance/.
11 Borrowers with federally backed mortgages could request up to 360 days of forbearance under P.L. 116-136 (or
longer, in some circumstances, based on administrative guidance); the expiration dates of individual forbearance plans
vary based on when they began and the length of forbearance requested by the borrower. T he foreclosure moratoriums
for federally backed mortgages expired after July 31, 2021.
12 For example, see a February 8, 2021, letter sent to congressional leaders at https://nhc.org/wp-content/uploads/2021/
02/Letter-to-Hill-re-Homeowner-Assistance-FINAL-2-8-21-with-signers.pdf.
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eligible entities, and some differences in how certain requirements (namely, deadlines for
requesting funds) apply to states and territories as compared to tribes and DHHL.
Of the $9.961 bil ion provided for the HAF, ARPA sets aside the following amounts:
 a total of $498.1 mil ion (5% of total funding) for tribes and DHHL;
 a total of $30 mil ion for the territories;
 up to $40 mil ion for Treasury for administration, oversight, and technical
assistance; and
 up to $2.6 mil ion for the Treasury Office of Inspector General (OIG) to provide
program oversight.
The remaining $9.4 bil ion is for al ocations to the states.
State and Territory Allocations
ARPA directed Treasury to al ocate funds to states (including the District of Columbia and Puerto
Rico) using a formula that referenced the average number of unemployed individuals over a
period of between 3 and 12 months and the number of mortgages more than 30 days past due or
in foreclosure in a state. It also established a minimum state al ocation of $50 mil ion.
Treasury developed a formula that used a four-month average of the number of unemployed
individuals on a seasonal y adjusted basis and the number of borrowers with mortgage payments
more than 30 days past due.13 It weighted the unemployment factor at 25% and the mortgages
past due factor at 75%. State al ocations are shown in Table 1.
Table 1. HAF State Allocations
(Dol ars in mil ions)
State
Amount
Alabama
$125.7
Alaska
$50.0
Arizona
$197.0
Arkansas
$63.3
California
$1,055.5
Colorado
$175.1
Connecticut
$123.1
Delaware
$50.0
District of Columbia
$50.0
Florida
$676.1

13 U.S. Department of the T reasury, Data and Methodology for State and Territory Allocations, April 14, 2021,
https://home.treasury.gov/system/files/136/HAF-state-territory-data-and-allocations.pdf. T reasury stated that it chose to
use past -due mortgages rather than mortgages in foreclosure because “ t he number of mortgagors with delinquent
mortgage payments better captures the homeowner need in each state because the rate of delinquent mortgage
payments has increased substantially since the beginning of the pandemic, while the rate of foreclosures has remained
relatively constant over the same period.” Foreclosure rates had remained relatively constant due to foreclosure
moratoriums covering many mortgages in response to the pandemic. T he foreclosure moratoriums for federally backed
mortgages expired after July 31, 2021.
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The Homeowner Assistance Fund in the American Rescue Plan Act: In Brief

State
Amount
Georgia
$354.2
Hawai
$50.0
Idaho
$71.9
Il inois
$386.9
Indiana
$167.9
Iowa
$50.0
Kansas
$56.6
Kentucky
$85.5
Louisiana
$146.7
Maine
$50.0
Maryland
$248.6
Massachusetts
$178.5
Michigan
$242.8
Minnesota
$128.7
Mississippi
$72.3
Missouri
$138.3
Montana
$50.0
Nebraska
$50.0
Nevada
$120.9
New Hampshire
$50.0
New Jersey
$326.0
New Mexico
$55.8
New York
$539.5
North Carolina
$273.3
North Dakota
$50.0
Ohio
$280.8
Oklahoma
$87.1
Oregon
$90.9
Pennsylvania
$350.4
Puerto Rico
$75.6
Rhode Island
$50.0
South Carolina
$144.7
South Dakota
$50.0
Tennessee
$168.2
Texas
$842.2
Utah
$66.0
Vermont
$50.0
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State
Amount
Virginia
$258.4
Washington
$173.2
West Virginia
$50.0
Wisconsin
$92.7
Wyoming
$50.0
Total
$9,390.4
Source: U.S. Department of the Treasury, Data and Methodology for State and Territory Al ocations, April 14, 2021,
pp. 2-3, https://home.treasury.gov/system/files/136/HAF-state-territory-data-and-al ocations.pdf.
ARPA set aside a total of $30 mil ion to be distributed among the territories (American Samoa,
Guam, the Commonwealth of the Northern Mariana Islands, and the U.S. Virgin Islands) based
on each territory’s population as a share of the combined population of all of the territories.
Territory al ocations are shown in Table 2.
Table 2. HAF Territory Allocations
(Dol ars in mil ions)
Territory
Allocation
American Samoa
$3.7
Guam
$13.6
Commonwealth of the Northern Mariana Islands
$4.2
U.S. Virgin Islands
$8.5
Total
$30.0
Source: U.S. Department of the Treasury, Data and Methodology for State and Territory Al ocations, April 14, 2021,
p. 4, https://home.treasury.gov/system/files/136/HAF-state-territory-data-and-al ocations.pdf.
Under ARPA, states and territories were required to request al ocated funds from Treasury within
45 days of enactment (i.e., by April 25, 2021). If there were remaining funds that were not
requested by that date, Treasury was to real ocate those funds among other eligible states within
180 days of enactment (i.e., by September 7, 2021). According to Treasury, al states and
territories requested their funding by the deadline.14
Tribal Allocations
ARPA provides that 5% of the total amount of funding for the HAF is for Indian tribes (or their
tribal y designated housing entities) that were eligible to receive grants under HUD’s Indian
Housing Block Grant (IHBG) program in FY2020 and DHHL.15 Five percent of the total funding
is $498.1 mil ion. Of that amount, 0.3% ($1.5 mil ion) is for DHHL.

14 T reasury’s HAF Guidance (as of August 2, 2021), p. 3.
15 Under the Indian Housing Block Grant, HUD provides formula funding to federally recognized tribes (including
Alaska Native villages and Alaska Native Corporations) or their tribally designated housing entities to use for
affordable housing activities. A small number of state-recognized tribes that received HUD assistance prior to the
establishment of the IHBG are also eligible. For more information on the Indian Housing Block Grant, see CRS Report
R43307, The Native Am erican Housing Assistance and Self-Determ ination Act of 1996 (NAHASDA): Background and
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The Homeowner Assistance Fund in the American Rescue Plan Act: In Brief

The remaining $496.6 mil ion is to be distributed to tribes using the same method required under
Treasury’s Emergency Rental Assistance Program.16 Namely, each tribe or its tribal y designated
housing entity is to receive the same proportion of funding that it received under the IHBG
formula in FY2020,17 with adjustments to al ow tribes that opted out of IHBG funding in FY2020
to choose to receive HAF funding.18 Treasury has said it wil announce tribal al ocations after a
tribal consultation process.19
The deadline for tribes and DHHL to request funds from Treasury is September 30, 2021 (rather
than the April 25, 2021, deadline that applied to states and territories).
Program Parameters
Once eligible entities—states, territories, tribes or their tribal y designated housing entities, and
DHHL—notify Treasury of their intention to participate in the HAF, Treasury is to provide funds
to these entities to use to assist eligible homeowners with certain al owable housing-related
expenses. Participating entities have discretion in how to use their funds and set up their
individual programs, within the parameters set by ARPA and related Treasury guidance.20
Homeowners are to apply for funding through the participating entity or its designee (e.g., a state
housing finance agency). A participating entity can set up one or more programs targeting
different populations of eligible homeowners or providing different types of assistance.
Eligible Uses of Funds21
ARPA provides that HAF funds are “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.” Qualified expenses specified in ARPA include the
following:
 Mortgage Assistance: Several eligible uses of funds are related to helping
homeowners with mortgage payments, including mortgage payment assistance,

Funding.
16 For more information on the Emergency Rental Assistance Program, see https://home.treasury.gov/policy-issues/
coronavirus/assistance-for-state-local-and-tribal-governments/emergency-rental-assistance-program.
17 Information on the IHBG funding formula, including formula allocation amounts, is available on the Department of
Housing and Urban Development’s website at https://www.hud.gov/program_offices/public_indian_housing/ih/
codetalk/onap/ihbgformula.
18 According to T reasury’s explanation of funding allocations for tribes under the Emergency Rental Assistance
Program, there are three tribes that opted out of IHBG funding in FY2020. See U.S. Department of the T reasury, Data
and Methodology for Allocations to Indian Tribes and Tribally Designated Housing Entities, January 19, 2021,
https://home.treasury.gov/system/files/136/Emergency-Rental-Assistance-Tribal-Data-and-Methodology-for-Pub-1-19-
21.pdf.
19 T reasury stated this on its Homeowner Assistance Fund website at https://home.treasury.gov/policy-issues/
coronavirus/assistance-for-state-local-and-tribal-governments/homeowner-assistance-fund.
20 T he structure of the program is similar to that of the Hardest Hit Fund, a temporary program created in 2010 to
respond to foreclosures in the wake of the 2007-2009 financial crisis and associated housing market turmoil. It
provided funds to select states to design foreclosure prevention programs that responded to local conditions. For more
information on the Hardest Hit Fund, see CRS Report R44805, The Hardest Hit Fund: Frequently Asked Questions or
https://www.treasury.gov/initiatives/financial-stability/TARP-Programs/housing/hhf/Pages/default.aspx.
21 Eligible activities are listed in Section 3206(c)(1) of P.L. 117-2 and T reasury’s HAF Guidance (as of August 2,
2021), pp. 3-5.
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The Homeowner Assistance Fund in the American Rescue Plan Act: In Brief

assistance to reinstate a mortgage (i.e., repay past due amounts to bring a
mortgage current), principal reduction, and facilitating interest rate reductions.
 Assistance with Certain Other Housing Costs: ARPA explicitly includes
assistance with certain other costs related to homeownership, including payment
assistance for utilities; internet service; homeowner’s, flood, or mortgage
insurance; and homeowners’ or condominium association fees or common
charges.
 Reimbursing Governments for Funds Previously Expended for These
Activities: ARPA allows funds to be used to reimburse a state, local, or tribal
government for funds it expended for related purposes between January 21, 2020,
and the date that the eligible entity first disburses HAF funds.
 Other Assistance as Determined by Treasury: ARPA provides that funds can
be used for “any other assistance to promote housing stability for homeowners,
including preventing mortgage delinquency, default, foreclosure, post-foreclosure
eviction of a homeowner, or the loss of utility or home energy services, as
determined by the Secretary.” Treasury’s HAF program guidance includes certain
other activities not specifical y mentioned in ARPA, including payment
assistance for delinquent property taxes and activities such as repairs to retain a
home’s habitability or assisting homeowners to obtain clear title in order to avoid
displacement. It also specifies that participating entities can use up to 15% of
HAF funds received for planning, community engagement, needs assessment,
and administrative expenses related to the HAF.
Eligible Homeowners
The HAF can be used to assist homeowners experiencing financial hardship after January 21,
2020.22 Treasury’s guidance requires homeowners to submit an attestation describing their
financial hardship.23
Al eligible homeowners must have incomes at or below 150% of area median income, and the
home must be a primary residence.24 The unpaid principal balance of a mortgage at the time the
mortgage was originated must not have exceeded the Fannie Mae/Freddie Mac conforming loan
limit.25
Targeting of Funds
Under ARPA, at least 60% of the funds made available to a participating entity must be used to
assist households with incomes at or below 100% of area median income or the median income
for the United States, whichever is greater.

22 T reasury’s August 2021 guidance clarified that this can include a hardship that began prior to that date but continued
after it. See T reasury’s HAF Guidance (as of August 2, 2021), p. 5.
23 T reasury’s HAF Guidance (as of August 2, 2021), p. 5.
24 T reasury’s HAF Guidance (as of August 2, 2021), p. 5.
25 See Section 3206(b)(4) of P.L. 117-2 and T reasury’s HAF Guidance (as of August 2, 2021), p.2. For more
information on the conforming loan limit, see the Federal Housing Finance Agency’s website at https://www.fhfa.gov/
DataT ools/Downloads/Pages/Conforming-Loan-Limits.aspx.
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The Homeowner Assistance Fund in the American Rescue Plan Act: In Brief

Remaining funds are to be prioritized to social y disadvantaged individuals. ARPA does not
define social y disadvantaged individuals for the purposes of the HAF, but Treasury included a
definition in its April 2021 guidance26 and a revised definition in its August 2021 guidance. The
definition adopted by Treasury in the August 2021 guidance reads as follows:
Socially disadvantaged individuals 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 Land, 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. 27
Funding Availability and Planning Requirements
Treasury’s guidance states that it wil make initial payments to participating entities in an amount
of 10% of their total al ocation once they sign a required agreement with Treasury and agree to
use funds only for eligible uses.28 To receive their remaining al ocations, entities need to submit a
detailed plan for their use of the funds for Treasury’s approval (a “HAF plan”).29
Treasury expects certain information to be included in a HAF plan, including information
describing the needs of eligible homeowners in the jurisdiction, the design of each program the
entity plans to implement, performance goals, and the entity’s readiness to implement the
program(s). Treasury has provided a template for eligible entities to use that includes the required
elements of the plan,30 as wel as a streamlined template for use by participating entities that
receive less than $5 mil ion in HAF funding.31 Participating entities can choose to submit multiple
HAF plans describing different uses of HAF funds, which may al ow certain activities to be
approved and implemented more quickly.32 Treasury set a deadline of August 20, 2021, for states
and territories to submit their HAF plans, or identify a date by which they intended to submit their
plans.33 This deadline did not apply to tribes.

26 T he definition included in T reasury’s April 2021 guidance was similar to a regulatory definition used by the Small
Business Administration at 13 C.F.R. Section 124.103. See T reasury’s April 14, 2021 , HAF Guidance, p. 2, at
https://web.archive.org/web/20210415164653/https://home.treasury.gov/system/files/136/HAF-Guidance.pdf.
27 T reasury’s HAF Guidance (as of August 2, 2021), pp. 2-3.
28 T reasury’s HAF Guidance (as of August 2, 2021), p. 6.
29 T he pandemicoversight.gov website provides some information on HAF funding that T reasury has obligated to
participating entities. See https://www.pandemicoversight.gov/track-the-money/funding-charts-graphs/pandemic-
response-funding and search for “ Homeowner Assistance Fund” under “ Assistance Listing.”
30 T he template is at https://home.treasury.gov/system/files/136/HAF-Grantee-Plan-Template.pdf.
31 T he streamlined template is at https://home.treasury.gov/system/files/136/HAF-Grantee-Plan-Template-under-
5M.pdf.
32 T reasury’s HAF Guidance (as of August 2, 2021), p. 7.
33 Originally, T reasury’s April 2021 HAF guidance set a deadline of June 30, 2021, for participating entities to submit
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Reporting Requirements
Treasury intends to require participating entities to submit quarterly reports with certain required
information, as wel as annual reports on the impact of the program. It states that it wil release
additional guidance on these reporting requirements in the future.34
Outstanding Questions
This section discusses certain broad, outstanding questions about the HAF, the answers to which
wil remain uncertain at least until states design and implement their programs, if not longer.
How will participating entities structure their programs?
As described above, funds from the HAF can be used for a range of qualified expenses to assist
eligible homeowners. Until Treasury approves participating entities’ HAF plans and they begin
implementing their programs, it wil be unclear to what extent each entity wil fund any specific
activity or what kinds of requirements they may place on the program or programs they create.
The National Council of State Housing Agencies has been tracking the progress of state HAF
programs and providing links to state-specific program information.35
Participating entities have significant discretion in designing their programs, including which
eligible activities to fund, which eligible homeowners to target, how homeowners wil apply and
what to require from applicants, and whether any additional requirements or conditions wil
apply. This discretion can al ow entities to develop programs that are responsive to housing
conditions and homeowner needs in their jurisdictions. However, the ability of participating
entities to establish various programs with different requirements also has the potential to cause
confusion or increase complexity for homeowners or mortgage servicers. In addition, some
observers have expressed concerns that if participating entities establish eligibility requirements
that go beyond those required by ARPA or Treasury guidance, it may unnecessarily limit the
ability of some homeowners to access assistance.36
The initial program guidance that Treasury released in April 2021, and its updated guidance
issued in August 2021, required or encouraged participating entities to prioritize certain types of
activities or ways of targeting assistance, which may influence participating entities’ decisions as
they develop their programs. Areas where Treasury encouraged certain actions include the
following:
 As noted earlier, Treasury made 10% of a participating entity’s al ocation
available initial y; to receive the remaining amounts, entities need to submit HAF
plans for Treasury’s approval. For the initial 10% payments, Treasury’s guidance
encouraged eligible entities to “use these initial payments to create or fund pilot

their HAF plans or a date by which they intended to submit their plans. T reasury later announced an extension of that
deadline to July 31, 2021, on its Homeowner Assistance Fund website. T he August 2021 guidance set a deadline of 14
days after the opening of an online portal that participating entities must use to submit their plans; the opening of the
online portal, and resultant deadline of August 20, 2021, was announced on the website.
34 T reasury’s HAF Guidance (as of August 2, 2021), p. 11.
35 See the National Council of State Housing Agencies website at https://www.ncsha.org/homeowner-assistance-fund/.
36 See, for example, “ Recommendations by Americans for Financial Reform Coalition for T reasury Department
Implementation of the Homeowner Assistance Fund,” March 17, 2021, pp. 3-4, https://www.nclc.org/images/pdf/
foreclosure_mortgage/mortgage_servicing/T reasury_HAF_Recs.pdf.
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programs to serve targeted populations, and to focus on programs that are most
likely to deliver resources most quickly to targeted populations, such as mortgage
reinstatement programs.”37
 In describing the required content of the HAF plans, Treasury’s August 2021
updated guidance says that entities “must” fund “one or more programs intended
to reduce mortgage delinquency among targeted populations.”38 (The original
April 2021 guidance had “strongly encourage[d]” this.) The guidance also
encourages entities to “consider program designs that leverage utility assistance
from other federal programs that have been created expressly for that purpose
before using HAF funds for utility assistance.”39
 Treasury’s August 2021 updated guidance encourages participants to consider
programs to preserve homeownership for low-income households, including
households without mortgages, in areas with rising property tax and utility
costs.40
 Treasury’s guidance encourages entities to prioritize assistance to homeowners
with mortgages backed by the Federal Housing Administration (FHA),
Department of Veterans Affairs (VA), or U.S. Department of Agriculture
(USDA), or those with mortgages funded through mortgage revenue bonds or
other programs that target low- or moderate-income homebuyers.41 To the extent
that these programs largely serve borrowers with incomes in the range to which
participating entities are to target most of their funds, focusing on borrowers with
these types of mortgages could help meet the program’s targeting requirements.
However, mortgages backed by FHA, VA, and USDA (or by Fannie Mae and
Freddie Mac) have been covered by CARES Act (P.L. 116-136) mortgage
forbearance provisions and a foreclosure moratorium for much of the pandemic,
whereas mortgages that are not backed by any of these entities may not have
benefitted from the same protections.42 Treasury’s August 2021 guidance also
notes that homeowners with mortgages that are not federal y backed may have
fewer assistance options and therefore be at greater risk of foreclosure, and states
that “the HAF plan must describe how the HAF participant wil determine and
address these needs.”43

37 T reasury’s HAF Guidance (as of August 2, 2021), p. 6.
38 T reasury’s HAF Guidance (as of August 2, 2021), p. 8.
39 T reasury’s HAF Guidance (as of August 2, 2021), p. 8.
40 T reasury’s HAF Guidance (as of August 2, 2021), p. 8.
41 T reasury’s HAF Guidance (as of August 2, 2021), pp. 8-9.
42 Estimates suggest that roughly 25% of single-family mortgages are backed by FHA, VA, or USDA and 46% are
backed by Fannie Mae or Freddie Mac, for a total of about 70% of mortgages covered by the CARES Act mortgage
protections. The remaining 30% of mortgages are not federally backed and were not covered by the CARES Act
provisions, although mortgage servicers may have provided forbearance or other assistance at their discretion. See
Karan Kaul and Laurie Goodman, The Price Tag for Keeping 29 Million Fam ilies in Their Hom es: $162 Billion , Urban
Institute, Urban Wire blog post, March 27, 2020, https://www.urban.org/urban-wire/price-tag-keeping-29-million-
families-their-homes-162-billion.
43 T reasury’s HAF Guidance (as of August 2, 2021), p. 9.
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The Homeowner Assistance Fund in the American Rescue Plan Act: In Brief

How effective will the HAF be?
It remains to be seen how effective the HAF wil be at achieving its stated goals of preventing
mortgage delinquencies, defaults, foreclosures, loss of utilities or home energy services, and
displacements for eligible homeowners. The extent to which the program achieves its goals could
depend on a variety of factors, including the following:
 How available funding compares to homeowner need: Estimating the total
number of homeowners in need, and the amount of assistance required, is
difficult due to a variety of factors. As of mid-June 2021, the Mortgage Bankers
Association, an industry group, estimated that there were about 2 mil ion
borrowers currently in forbearance44; as of early September 2021, it estimated
that number to be 1.5 mil ion.45 While the number of borrowers in forbearance
gives a sense of how many homeowners are having difficulty making mortgage
payments, not al homeowners in forbearance wil require assistance when
forbearance ends. Many homeowners who have exited forbearance to date have
been able to resume payments and enter into agreements to repay past due
amounts or have otherwise paid off their mortgage debt (e.g., by refinancing or
sel ing the home).46 The Consumer Financial Protection Bureau notes, however,
that those who remain in forbearance longer may be in deeper financial distress
and wil owe more in missed payments upon exiting forbearance.47 While not al
homeowners currently in forbearance wil necessarily require additional
assistance, some homeowners in need of assistance may not have mortgages in
forbearance. They may be behind on mortgage payments but not qualify for
forbearance, or they may be current on mortgage payments (or not have a
mortgage) but be having difficulty meeting other costs, such as property tax
payments or association fees.
 How quickly programs are set up and homeowners can access funding:
Participating entities are in the process of designing and implementing their
programs and opening them up for homeowners to apply for funding. The
amount of time it takes to design and implement programs, including having
plans approved by Treasury, could affect how many eligible homeowners are able
to access assistance.
 The types of assistance provided and program criteria: Other factors that wil
affect HAF’s effectiveness at achieving its goals may include the types of
assistance participating entities choose to provide and how restrictive eligibility
and program criteria are. Additional eligibility requirements or restrictions on
how funds can be used could reduce the number of homeowners who would

44 Mortgage Bankers Association, “Share of Mortgage Loans in Forbearance Decreases to 3.93%,” press release, June
22, 2021, https://www.mba.org/2021-press-releases/june/share-of-mortgage-loans-in-forbearance-decreases-to-393.
45 Mortgage Bankers Association, “Share of Mortgage Loans in Forbearance Decreases to 3.08 Percent,” press release,
September 13, 2021, https://www.mba.org/2021-press-releases/september/share-of-mortgage-loans-in-forbearance-
decreases-to-308-percent.
46 T he Mortgage Bankers Association forbearance survey includes information on forbearance exits and resolutions.
See, for example, “Share of Mortgage Loans in Forbearance Decreases to 3.08 Percent,” press release, September 13,
2021, https://www.mba.org/2021-press-releases/september/share-of-mortgage-loans-in-forbearance-decreases-to-308-
percent .
47 Consumer Financial Protection Bureau, Housing insecurity and the COVID-19 pandemic, March 2021, pp. 11-13,
https://files.consumerfinance.gov/f/documents/cfpb_Housing_insecurity_and_the_COVID-19_pandemic.pdf.
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The Homeowner Assistance Fund in the American Rescue Plan Act: In Brief

 qualify for assistance or make it more difficult for some to access funding.
Treasury’s August 2021 guidance “discourages” participating entities from
“imposing additional eligibility criteria such as foreclosure status, credit score,
bankruptcy status, the existence of liens on the property, or previous cash-out
refinances.” It directs that entities seeking to include additional eligibility criteria
“must explain with specificity how those criteria would further the objectives of
the HAF, including how they would help the program reach eligible
homeowners.”48

Author Information

Katie Jones

Analyst in Housing Policy

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48 T reasury’s HAF Guidance (as of August 2, 2021), p. 6.
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