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HAFP-0197-Alaska

Treasury Feedback for Resubmission of Plan

Please revise the HAF plan by providing a response to the questions below.

Completeness

 No questions.

Homeowner Needs and Community Engagement

Data

 No questions.

Community Engagement and Public Participation

 Your plan indicates that only 1 organization involved in your public input process primarily 

serves low- or moderate-income populations or addresses housing discrimination. Please 

explain how the program is confident in its ability to reach targeted populations without 

engaging such organizations in planning and implementation.

Alaska Housing Finance Corporation (AHFC) is also the Public Housing Authority for the entire state 

of Alaska. In addition to our Public Housing and Housing Choice Voucher (aka Section 8) funds, we 

administer several state and federal homeless and supportive service grants throughout the state 

via 30+ nonprofit housing partners. Additionally, AHFC works collaboratively with the Association 

of Alaska Housing Authorities (AAHA) to coordinate efforts with our regional housing authority 

partners who serve tribal members throughout the Alaska. 

Directly and through our grantee partners, AHFC has extensive experience addressing housing 

discrimination by providing housing opportunities to low-or moderate-income populations. These

strong and sustainable partnerships with non-profit social service agencies, Community Housing 

Development Organizations and other government agencies help ensure that program goals are 

met and that all target populations are reached by program outreach and enrollment efforts. 

Most recently, our partnerships with the grantee and AAHA partners were leveraged to support 

the outreach and implementation of the Emergency Rental Assistance Program. Our collective 

efforts resulted in 10% of the statewide population responding with applications (1/3rd of all rental 

units in the state). The under-represented minority populations were over-represented in our 

application response and over 80% of the applications were from households at or below 50% area 

median income.

We intend to move forward with a similar outreach plan with our partners to ensure full statewide 

coverage and access for all Alaskans, with particular focus given to the service areas of our tribal 

partners who in many cases serve regions off the road system with disparate access to technology. 

 Your plan notes public input and community engagement in the plan development process. 

Please explain how community engagement informed your plan’s programmatic and outreach 

design.

During the open public comment hearings, members of the public and partner organizations offered 

input that provided insight on housing needs that are unique to Alaska. Due to a large and diverse 

geographic area, Alaska has distinctive rural characteristics which include large regions of the state that 
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are not connected to the road system. Engaging with our tribal and non-profit partners and members 

of the public in these hearings helped inform us of different regional challenges that need to be 

addressed when designing the program plan and outreach efforts.

AHFC also hosted community engagement opportunities for loan servicers and the Association of 

Alaska Housing Authorities (AAHA) which represents Alaska’s 14 regional housing authorities. 

Collectively, these 14 housing authorities represent nearly 200 federally recognized tribal entities. The 

partnership with AAHA members was instrumental in the implementation of the Emergency Rental 

Assistance program and we expect it to be integral to the HAF program outreach and implementation 

as well. The dialog and engagement helps ensure that programmatic and outreach design includes 

input from partners with regional expertise on housing and homeowner needs.

 Please provide an update on your efforts to coordinate with Tribes and AlaskanNative 

Corporations.

In the dialogue with the Association of Alaska Housing Authorities (AAHA), several of the tribally 

designated housing entity members expressed interest in partnering with AHFC to develop their HAF plans. 

Collectively, AAHA represents nearly 200 federally recognized tribal entities. During the Emergency Rental 

Assistance Program, 12 organizations representing federally recognized tribes partnered with AHFC to 

leverage shared infrastructure and 10 participated as funding partners. 

AHFC is working with several of the AAHA member organizations to develop strategies to help streamline 

outreach and programmatic efficiencies such as collaborating to develop a statewide HAF registration 

portal that can be used by tribally designated housing entities. 

 Please provide an update indicating any public comments you have received since you 

submitted your HAF Plan, from which organization you received any such comment, and 

whether you have responded to the comments.

During the two public comment hearings, AHFC recorded the audio of the meetings. Many of the 

general comments and questions were answered live during these hearings and can be viewed in 

the meeting transcripts. 

In addition to comments from the general public, several organizations also submitted comments 

and questions including:

Anchorage Coalition to End Homelessness

Alaska Coalition to End Homelessness

Brother Francis Shelter

Association of Alaska Housing Authorities

Cook Inlet Housing Authority

HUD, Anchorage Field Office

Northwest Inupiat Housing Authority

All questions and comments regarding the HAF plan have been responded to.

Ongoing Assessment of Homeowner Need

 Please explain how the program will address changes in homeowner needs in the comingyears.

The program design is flexible to help address different homeowner needs on an individual basis. Program 
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funds can be allocated to mortgage payment assistance, mortgage reinstatement, mortgage principal 

reduction, payment assistance for utilities, insurance, homeowner or condominium association fees and 

property taxes. Since some homeowners may experience a Covid-19 hardship that could affect one or all of 

these categories, AHFC will be able to support homeowners based on their individual needs. Over time, the 

program will be able to adapt to changing homeowner needs since homeowners can qualify for different 

types of assistance that are included in the program umbrella.

Program Design

 Will there be a method in your HAF program, early in the process of engaging with a household, 

to evaluate immediate threats to the housing stability of applicants, which may need to be 

addressed under an expedited or prioritized timeline (e.g., HOA liens, tax delinquencies, utility 

shut off)?

Yes. In the application portal, homeowners will be asked a series of questions that will evaluate the 

stability of their housing and identify immediate threats to their housing status. Applicants who are 

experiencing an immediate threat to their housing stability will be prioritized and their applications will 

be processed before applicants who indicate they have a relatively stable housing status. Applicants will 

also be provided information about other potential resources and programs from their servicers and will 

be referred to a housing counseling agency that may assist homeowners with their HAF application and 

to help identify additional resources. Applicants will also provide shut-off and delinquency letters to help 

AHFC prioritize immediate homeowner needs.

 Please describe how your program will utilize housing counselors or legal services to assist 

homeowners in evaluating loss mitigation options available for their mortgage. Your description 

should include:

o whether your program will connect homeowners with housing counseling or legal 

services early in the process.

o the role housing counseling or legal services providers will play in supporting 

homeowners’ efforts at engaging in loss mitigation.

As part of the application process, homeowners will be referred to additional resources that may help 

them stabilize their housing status including housing counseling or legal services. All applicants will receive 

a referral when they first apply for assistance in the application portal. Housing counseling and legal 

services can help homeowners identify additional resources and may help homeowners work through the 

process of loss mitigation when they are working with their mortgage servicer.

Borrowers are encouraged to work with a housing counselor that is provided by their mortgage servicer

through the loss mitigation process. Through a servicer, housing counselors can review a borrower’s 

current and full financial situation and provide guidance and options available. 

 How will your program leverage resources available through a loss mitigation process to benefit 

eligible homeowners and how will your program avoid using HAF funds in ways that duplicate 

relief that available loss mitigation options might provide? In particular, when HAF assistance will 

be limited to payments for mortgage reinstatement, please explain whether and how you will 

assess what loss mitigation may be available through the servicer.

If a homeowner has a mortgage and has not worked with their servicer to go through a loss mitigation 
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process, AHFC will strongly encourage the homeowner to talk with their servicer about their loss 

mitigation option. If a homeowner has already gone through loss mitigation and is still experiencing a 

Covid-19 hardship, they may qualify for monthly homeowner assistance. AHFC will encourage 

homeowners to leverage resources available through loss mitigation but will not require loss mitigation

to receive HAF assistance.

Many borrowers should be expected to work with their servicers for loss mitigation options available 

first. Servicers are required to follow Investor, Guarantor, and Insurer guidelines as they work with 

borrowers through loss mitigation.

 Please explain what steps, if any, your program will take to assist the homeowner in determining 

whether a HAF-resolution will result in a sustainable monthly payment?

As part of the application, homeowners will be asked to submit their current monthly household income 

and expenses. AHFC will work with the homeowner to identify additional resources such as loss 

mitigation with their servicer to help supplement HAF funds. Although AHFC will have some information 

that may help evaluate if the HAF-resolution will result in a sustainable monthly payment, homeowners 

will not be disqualified from HAF if their current monthly income does not achieve a sustainable level to 

maintain current expenses.

For borrowers working with their servicer on loss mitigation, AHFC will use the underwriting detail from 

the Common Data File (CDF) to help evaluate the sustainability of a borrower’s ability to make ongoing 

payments and will work with borrowers and their servicers to identify additional resources.

 Are you anticipating increased winter home energy costs and their potential impact on the 

homeowners that HAF will serve?

Yes, home energy costs typically increase during winter months. We anticipate that some 

homeowners may need more utility assistance during winter months due to increased energy and 

heating expenses.

 Your programs set $20,000 as the maximum amount of assistance per homeowner. Please 

explain how you determined this amount will be sufficient to resolve housing-related 

delinquencies and whether the cap will be sufficient in areas with higher housingcosts?

The $20,000 program maximum amount was determined as part of the data analysis process. In 

addition to the federal lending data, AHFC extrapolated our internal mortgage data to estimate the 

level of homeowner need for Alaska. The percentage of homeowners in AHFCs portfolio which were

delinquent or in forbearance was used to extrapolate the total need in Alaska based on AHFCs share 

of statewide mortgages. Although alternative maximum amounts were considered, $20,000 was 

decided based on the data analysis and estimate of the number of homeowners in need statewide

and the estimate of the total financial need across the state. Since the request for funds might 

exceed the amount of total funds available, we found it was necessary to establish an upper limit 

for assistance per household to facilitate representative service delivery for the entire State. 

Eligibility

 Please provide the rational for not using a fact-specific proxy as one method for establishing 

eligibility under your plan, including how you determined that without such a proxy, your 

program can avoid unnecessary barriers to participation by eligible homeowners.
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Although AHFC is not planning to use a fact-specific proxy to establish income eligibility, we are 

planning to use self-attestation to help avoid unnecessary barriers to participation by eligible 

homeowners. AHFC also plans to use a fact-specific proxy to help target outreach efforts by focusing 

on zip codes that tend to have low income rates and high rates of socially disadvantaged populations.

Requiring some documentation will help ensure the best outcome for the borrower when using HAF 

funds.

In our administration of the Emergency Rental Assistance Program, we were able to conduct a 

limited review of income documentation for eligibility without disrupting service delivery. With over 

30,000 applications to review, our team was able to complete the income reviews for over 25,000 

households within a matter of 3 weeks. We understand that other states were not able to do this, 

but we were. The net effect is that we identified over 1,000 households that were substantively 

over-income that had requested tens of millions of dollars in program funds. Our review enabled us 

to ensure those funds were instead used for households that were truly very low-income.

In our experience, limited due-diligence and expeditious service delivery were not mutually exclusive 

goals. We have the staff and technical infrastructure in place and to complete any income reviews 

quickly. 

Outreach

 Please explain how the program will target outreach and provide access to homeowners with 

limited English proficiency.

Building on its successful marketing of the emergency rental assistance program, AHFC has already 

collected more than 8,000 email addresses from the public interested in HAF. AHFC will leverage its 

relationships with the banking community as well as other relevant organizations including tribal 

authorities, Alaska Legal Services, statewide courts, local school districts and libraries, and others to 

share relevant messages about the program and actively encourage participation. Paid print and radio 

advertising will include messages shared in Spanish and Tagalog. AHFC will utilize Google Translate 

and leverage its existing websites (www.AHFC.us and www.AlaskaHousingRelief.org) and its 

application portal, allowing for translations in 108 languages. Online social engagement and digital 

advertising will be robust, driving awareness about the program and encouraging Alaskans to 

participate. Our online efforts will be monitored and adjusted as required throughout the duration of 

our campaign. All materials will be available for download on our website, and we’ll develop 

additional collateral by request.

 Please explain how the program will provide culturally relevant marketing.

In addition to materials developed in the their native language, AHFC will choose imagery that is culturally 

appropriate for the region that is targeted. AHFC will work with rural and supporting partner organizations 

to help disseminate program information through traditional and modern means, and we’ll make all 

resources available on our website and provide an opportunity for the public to request additional 

materials.

 If your program intends to serve households who are over the 100% AMI threshold, how will 

your program prioritize Socially Disadvantaged Individuals?

AHFC will provide targeted communications and outreach to communities and zip codes that are 

known to have large proportions of Socially Disadvantaged individuals. Increasing outreach efforts in 
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these areas should increase the number of Socially Disadvantaged individuals who apply for HAF 

assistance. AHFC will track the number of applicants and recipients through the HAF portal to 

prioritize and ensure that the targeted proportion of Socially Disadvantaged individuals receive HAF 

assistance is met.

Performance Goals

 Please explain how you intend to communicate your progress towards performance to the 

public.

AHFC will host regular debriefings with partner organizations to help disseminate program progress 

and performance. AHFC will also host a HAF website that will have HAF information, additional 

homeowner resources, and program progress and performance details that will be updated on a 

regular basis.

In addition to these briefings, AHFC maintains a dashboard that is updated on a weekly basis for the 

Emergency Rental Assistance Program. This dashboard https://www.ahfc.us/newsroom/alaskahousing-rent-relief-weekly-program-update includes programmatic data elements and maps 

outcomes by census tract and zip code. We anticipate developing similar accountability / 

transparency dashboards for the HAF program once it becomes operational.

 Please indicate which three metrics will serve as the best indicators of the success of your 

program.

1. Geographic and demographic representation of Alaskans served HAF funding.

2. Speed and equity of funding distributed to HAF recipients by recipient income range.

3. Number of Socially Disadvantaged Alaskans provided with HAF assistance.

 Please indicate whether you intend to disaggregate metrics by income, race, gender, etc.

Yes. The application portal will collect income, race, gender and other informative metrics that we will use 

for performance evaluation and reporting purposes. We analyzed these data points on a weekly basis for 

the Emergency Rental Assistance program to ensure no gaps developed through program outreach or

service delivery and will continue to do so with the HAF. 

 Please consider including as an additional metric the number of homeowners 

assisted/foreclosures prevented solely through counseling or legal services without payment of 

HAF funds to resolve the homeowner’s defaults or delinquencies.

Yes. We will track referrals to counseling or legal services and request outcomes information from 

those agencies. 

Readiness

 Please provide the most recent available information about your program's readiness, including 

staffing, contractors, etc.

AHFC will utilize staff currently employed by AHFC. AHFC will also utilize temporary staff who are 

currently working on the Rental Relief Program such as call center staff. Gere Tactical is currently 

working as a contractor to design and maintain the online application portal. 
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At present, our internal AHFC resources for this program are a team of 26 temporary call center staff, 5 

full time permanent staff, 6 project based staff, 3 contract staff for systems maintenance and 100+ 

dedicated processing team staff with our nonprofit partners. 

Our Emergency Rental Assistance Program staff can be repurposed to manage the HAF program. We 

intend to have the same team review income eligibility and to provide support for program inquiries and 

escalations. The application system for the Emergency Rental Assistance was developed with the 

expectation that a Homeowner Module would be needed, so the infrastructure for the application 

intake, data management, and workflow is largely in place.

When Treasury grants us approval to move forward, we will be ready to market the program and open 

the application system within a matter of weeks. Our hope and goal is to be able to launch the outreach 

before the holiday season ends.

 Is your program prepared to launch upon approval and, if not, by what date will you be ready to 

launch following approval?

We anticipate that the registration portal will be ready to open by December 15th. 

 Please provide updated information about your progress in spending the initial 10% payment 

from your jurisdiction’s full allocation and the status of any pilot assistance already offered or 

made available to homeowners.

Alaska did not operate a HAF pilot program or spend the initial 10% payment.

Budget

No questions