1 of 7

RESPONSES TO US TREASURY QUESTIONS REGARDING STATE OF NEVADA HAF PLAN

Revised 1/13/2022

HAFP-0064 State of Nevada 

Treasury Feedback for Resubmission of Plan 

Please revise the HAF plan by providing a response to the question(s). 

Completeness 

No questions. 

Homeowner Needs and Community Engagement Data 

No questions. 

Community Engagement and Public Participation 

• 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. 

Response: NAHAC held initial roundtables with servicers and HUD-approved Housing 

Counseling Agencies (HCA) to discuss development and implementation of Nevada’s HAF 

plan. The plan has been shared with stakeholders and NAHAC has received relevant 

feedback. Follow-up roundtables were held to vet stakeholders’ input, and a public hearing 

was held on July 12, 2021, where homeowners, servicers, HCAs, and other stakeholders had 

the opportunity to make comments and participate in the HAF plan discussion. Regular 

discussions were also held with state and local legislative officials. 

Based on the data reported on Nevada’s state unemployment rates and mortgage delinquency 

rates, NAHAC intends to engage HCAs and legal aid centers to assist targeted groups 

including individuals considered socially disadvantaged, collecting unemployment benefits, 

experiencing financial hardships and/or mortgage delinquency, or facing foreclosure. 

NAHAC will also work closely with local jurisdictions and government officials to understand 

homeowners’ needs, including offering multiple intake formats and provide additional 

pathways into the program, as well as providing both cultural and linguistic relevant 

outreach. 

• Please describe any coordination you intend with Tribes or Tribal entities. 

Response: Nevada is not planning any coordination with Tribes or Tribal entities at this 

time.

• 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. 

Response: Please see response to first bullet of Community Engagement and Public 

Participation above.
2 of 7

Ongoing Assessment of Homeowner Need 

No questions. 

Program Design 

• Please explain how the sources of data listed in the section on Homeowner Needs informed the 

Program Design Elements included in your plan. 

Response: Data from the U.S. Bureau of Labor Statistics (2021) showed that all counties 

across Nevada experienced increased unemployment rates at the height of the pandemic. 

The pandemic brought about temporary closure of the service industry, particularly hotels, 

casinos, and restaurants. Some of these businesses remain fully or partially closed today. At 

the peak, Nevada’s unemployment rate rose from 3.7% in February 2020 to 29.5% in April 

2020 due, in part, to the closure of major casinos, which employ approximately 206,000 

workers. The unemployment rate in the state as of April 2021 was 8%, 6th highest rate in 

the country and more than double the rate prior to the pandemic. Additionally, according 

to CoreLogic Market Trends, Nevada’s delinquency rate rose from 1% in April 2020 to 6%

in August 2020.

In September 2020, Nevada ranked #2 at almost 21% on the Housing Hardship Index, with 

a 12.6% unemployment rate, and 8.3% delinquency. The lack of work has had a dramatic 

impact on Navadans’ ability to pay their mortgage and/or household bills. Mortgage 

delinquencies on government backed loans are reported to be approximately 24%, and an 

additional 9% of homeowners have entered into forbearance agreements.

Based on this data Nevada decided to rollout the Unemployment Mortgage Assistance 

(UMA) and Mortgage Reinstatement Assistance Program (MRAP) to address the great 

need of Nevada homeowners who are dealing with pandemic related unemployment and 

delinquency.

• 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)? 

Response: Early in the application process homeowner needs with be assessed through a 

triage process. It is anticipated that most of the households will be experiencing housing 

instability or immanence. Nevada will collaborate with HCAs and legal aid services as 

necessary to address some of those immediate threats while the homeowner’s application is 

going through the process.

• Please confirm your exclusion of reverse mortgages, contracts for deeds/land contracts, and 

second mortgages and explain what steps you have taken to assess the needs of homeowners with 

these mortgage types. Please summarize any community feedback or data on which you have 

based this decision. 

Response: Nevada will research further to determine if there is a need to assist reverse 

mortgages or 2nd mortgage loans. 
3 of 7

Follow-up Question from Treasury dated December 20, 2021:

Please update this response if necessary.

Updated Response (12/27/2021): On November 29, 2021, NAHAC received a report from 

US Treasury on data as of September 30, 2021, regarding the Federal Housing 

Administration’s (FHA) Home Equity Conversion Mortgages (HECMs). The report 

indicated that there are 7,658 active HECM loans in Nevada, which represent 1.4% of all 

active HECM loans in the nation. Of the 7,658 active HECM loans, it is reported that 352 

(4.6%) are in a COVID-19 extension, which indicates there is not a great need at this time 

that would warrant the creation of an additional program. However, we will continue to 

monitor this subset of loans to determine if a change of course is necessary in the future.

Follow-up Question from Treasury dated January 4, 2022:

On reverse mortgages - many states are not creating a separate program for reverse mortgage 

borrowers, but assisting these homeowners through their reinstatement programs, with funds used 

to bring them current on tax/insurance obligations. Is that something Nevada would consider?

Updated Response (1/13/2022): Nevada will review to determine how best to service the 

subset of homeowners who would need assistance in bringing taxes and insurance current. 

• 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. 

Response: Nevada posted a Request for Proposal (RFP) for HCAs and anticipates

contracting with multiple HCAs and local legal aid services. Nevada will also conduct

ongoing meetings with HCAs and legal aid services to assist homeowners in evaluating loss 

mitigation options available through their servicer.

HCAs will participate in outreach and community events, including open houses. HCAs will 

also assist homeowners with pre-eligibility, one on one counseling, and applications. 

Homeowner education classes are expected to be conducted by HCAs to include topics such 

as Loss Mitigation and Foreclosure Prevention. Additionally, homeowners can be readily 

connected with an HCA as early as the initial pre-screening process. 

• 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? 

Response: Homeowners will be required to engage with their mortgage servicer before 

applying for HAF funds. During the pre-screening process, homeowners are asked if they 

have reached out to their servicer. If the answer is no, they will not be able to proceed with 

their application and will be instructed to contact their servicer before re-applying for HAF. 
4 of 7

Follow-up Question from Treasury dated December 20, 2021:

During our conversation, you indicated that you would be taking steps to follow up with these 

homeowners and potentially connect them with housing counseling. Could you elaborate on what 

steps your program will take?

Updated Response (12/27/2021): During pre-screening, homeowners are asked if they have 

engaged with their mortgage servicer for mitigation options prior to moving to the 

application stage. If the answer is no, the homeowner will be deemed ineligible, and advised 

via a message on the screen to contact a HUD approved housing counseling agency to assist 

the homeowner with loss mitigation options and/or credit counseling. Likewise, if a 

homeowner is deemed ineligible after the application process, they will also be referred to a 

housing counseling agency.

Follow-up Question from Treasury dated January 4, 2022:

For homeowners who apply without having first sought loss mitigation, you have framed this as 

an eligibility requirement. I want to make sure that is the right term.

o Nevada’s MRAP Term sheet does not indicate this is an eligibility requirement. That 

terminology could be confusing for homeowners (and perhaps you don’t intend to convey 

this as an eligibility requirement). “Ineligible” connotes something more permanent that 

may discourage homeowners from getting help from HAF, including those homeowners 

who are frustrated or don’t understand the loss mitigation process.

o In addition, as we have mentioned, stewarding these homeowners towards exploring loss 

mitigation (including through housing counselors), is something for which HAF 

programs can and should take credit. Perhaps the terminology is only internal, but it may 

be helpful to think through how this will be communicated both to individual 

homeowners at the pre-application/application stage and to those advocates and the 

public to avoid confusion regarding Nevada’s process. 

o Also, it may help to consider waivers to this requirement where a homeowner has a 

privately-backed mortgage with limited loss mitigation options or encounters poor 

handling of their loss mitigation application by the servicer, to ensure these homeowners 

don’t fall through the cracks.

Updated Response (1/13/2022): After further discussion, Nevada will not require

homeowners to leverage resources available through a loss mitigation process. Instead, 

during the application process, homeowners will be asked if they have engaged with their 

mortgage servicer for loss mitigation options. If the answer is no, the homeowner will be 

advised via a message on the screen to contact a HUD approved housing counseling agency 

to assist the homeowner with loss mitigation options and/or credit counseling and will then 

be allowed to proceed with a HAF application.

• 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? 

Response: Nevada is launching two foreclosure prevention programs, Unemployment 

Mortgage Assistance (UMA) and the Mortgage Reinstatement Assistance Program

(MRAP). These programs are not intended to assist in lowering the monthly mortgage 

payment. They are intended to provide temporary assistance, such as reinstatement of the

mortgage and/or monthly mortgage payment assistance. As the needs of homeowners in 

Nevada are further assessed, Nevada will determine if additional programs are required. 
5 of 7

Follow-up Question from Treasury dated December 20, 2021:

During our conversation, you indicated that you would be taking steps to assess 

sustainability. Could you expand on your answer by providing an overview of these steps?

Updated Response (12/27/2021): The Mortgage Reinstatement Program (MRAP) will help 

homeowners that suffered a significant financial hardship during the pandemic but have

overcome that hardship and can sustain their monthly mortgage payments going forward. 

NAHAC has established affordability as having a housing-to-income ratio of less than or 

equal to 33%. The FHA uses 31% of income towards housing costs and applied an 

additional 2% as margin of variation. Homeowners with housing-to-income ratio greater 

than 33% will be considered to not have a sustainable monthly payment and will be deemed 

ineligible. In these cases, homeowners will be referred to a HUD approved housing 

counseling agency to assist the homeowner with loss mitigation options and/or credit 

counseling. Nevada’s HAF programs will be continuously monitored to determine if 

changes are required. 

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

homeowners that HAF will serve? 

Response: Nevada is not expecting winter increases outside of the norm. However, 

homeowners experiencing higher than usual energy costs or difficulty paying energy bills 

will be referred to Nevada 211 for additional resources such as weatherization, Energy 

Assistance Program (EAP), Equal Pay and other mainstream programs. 

Eligibility 

• Please provide the rationale for establishing the following additional eligibility requirements 

specified in your plan, including how you determined these requirements will not create 

unnecessary barriers to participation by eligible homeowners: 

o Affidavit of Unemployment 

o Social Security Card 

o Documentation of DETR UIB at time of application or within 90 days from application. 

Response: The Nevada Homeowner Assistance Fund System portal (HAFS) is programmed 

to provide homeowners with an Unemployment Affidavit, which homeowners will execute 

electronically, which, therefore, does not create unnecessary barriers. The requirement of a 

Social Security Card is only needed from borrowers obligated on the mortgage and related 

spouse/Registered Domestic Partner. This documentation is requested to reduce fraud and 

maintain the integrity of the program. Additionally, homeowners are able to upload 

required documents, including copy of Social Security Card and DETR Unemployment 

Insurance Benefit (UIB). The UIB is requested for the UMA program to determine if the 

homeowner is receiving unemployment benefits at time of application or within the prior 

90-day period. If homeowners do not have access to upload documents, they can fax or mail 

the documents. Homeowners may also work with a HCA to assist with their documents. 

Follow-up Question from Treasury dated December 20, 2021:
6 of 7

During our conversation, you indicated that an ITIN card or other identification information may 

also be a permissible form of documentation. Please confirm whether this is the case and, if so, 

update your response to note this.

Updated Response (12/27/2021): Homeowners obligated on the mortgage, including spouses 

and Registered Domestic Partners, will be required to provide their social security card or 

Individual Taxpayer Identification Number (ITIN) document as permissible forms of 

documentation. Homeowners that do not have either a social security number or ITIN will 

be deemed ineligible. This information is used for identification purposes to prevent fraud, 

and it is also being used as a unique identifier per borrower and to ensure household 

assistance does not exceed program specific and overall household allotted maximums. 

Outreach 

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

limited English proficiency. 

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

Response: Nevada has identified the top 3 languages in our state as being English, Spanish, 

and Tagalog. Nevada has contracted with a marketing firm to develop a marketing and 

public relations plan, including a social media component, to targeting the socially 

disadvantaged, underserved, low income, and different ethnic groups as well as those with 

limited English proficiency based on demographic data. 

Prioritization 

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

your program prioritize Socially Disadvantaged Individuals? Please describe your marketing and 

outreach strategy to SDI communities? 

Response: The HAFS portal will flag applicants that have self-identified as being a Socially 

Disadvantaged Individual for prioritization purpose. It will also flag and prioritize the 

households who are under the 100% AMI threshold by using the HUD AMI table. Lastly, 

the system has also been programmed with majority/minority census tracts based on the 

2019 Nevada Census Tracts. 

Performance Goals 

• Please explain how you intend to communicate your progress towards performance to the public. 

Response: Once program progress metrics are clearly defined, Nevada plans to post 

progress reports on NAHAC’s website. 

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

program. 

Response: Three metrics that may serve as indicators of the success of the HAF program

include the number of homeowners assisted (funded), retention rate of homeownership 

after assistance, and the percentage of homeowners assisted that were considered socially 
7 of 7

disadvantaged or under 100% AMI. Performance metrics may change as further guidance

and requirements are defined by US Treasury.

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

Response: The HAFS portal has the ability to provide the demographics in question. 

However, reports will be designed in accordance with US Treasury reporting requirements

once they are received. 

• 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. 

Response: Nevada has considered this and will be including this in the required reporting 

from partnering HCAs and legal aid services.

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

staffing, contractors, etc. 

Response: NAHAC is almost fully staffed with 12 full-time regular employees, and 5 

temporary employees in various positions primarily focused on the Nevada Homeowner 

Assistance Fund program. Additionally, NAHAC has acquired vendor contracts for the 

following services: system of record, legal services, data services, Processing and Eligibility 

services, accounting services and quality assurance. 

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

launch following approval? 

Response: NAHAC soft launched a pilot program on Monday, 11/15/2021 and is now taking 

applications for HAF. 

• 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. 

Response: Approximately $548,000 has been expended to date, which includes capitalized 

assets for the new system and related implementation costs which will be depreciated over 

time. 

Budget 

No questions