Page 1 of 25

HAF Grantee Plan - HAFP-0040 -Agency of Commerce and Community Development - Extracted

 02/15/2022 18:41:55

United States Department of the Treasury

Homeowner Assistance Fund Plan

Submitted by Agency of Commerce and Community Development

HAF Grantee Plan Name

HAFP-0040
Page 2 of 25

HAF Grantee Plan - HAFP-0040 -Agency of Commerce and Community Development - Extracted

 02/15/2022 18:41:55

United States Department of the Treasury

Homeowner Assistance Fund Plan For Participants 

with Allocations $5 million or Greater

Allocation Amount $5 Million or Greater

Submission Date 12/3/2021 8:55 AM

Total Plan Requested Amount $49,997,817.00

Record Type State

Application Record SLT-0007

HAF Grantee Plan Status (external) Funded
Page 3 of 25

HAF Grantee Plan - HAFP-0040 -Agency of Commerce and Community Development - Extracted

 02/15/2022 18:41:55

Homeowner Needs and Community Engagement

What Quantitative Data Has Informed the Participant’s Planning?

Treasury will assess the extent to which a Participant has, in the course of its HAF planning process, relied on

quantitative data, including from community-based organizations or organizations that serve potentially

eligible homeowners. 

In its HAF planning process, has the Participant obtained quantitative data from mortgage servicers, private

data providers, government entities, community-based organizations, or other sources to inform its planning

about how to target and best serve eligible homeowners with mortgage delinquencies, defaults, foreclosures?

Yes

If yes, please list and, briefly describe each source of quantitative data.

The Participant, State of Vermont, Agency of Commerce and Community Development,

Department of Housing and Community Development is granting the HAF funds to the Vermont

Housing Finance Agency (VHFA), body politic and corporate and public instrumentality of the

State tasked with serving Vermont Homeowners, to implement Vermont’s HAF program. VHFA

has used the most accurate sources available to plan and target HAF resources to eligible

homeowners facing mortgage delinquency, default and foreclosure including the following: 

Data provided by mortgage servicers – Numbers and amount owed for Vermont mortgages by

investor and delinquency and foreclosure status were provided by US Bank, the largest mortgage

servicer. In addition, VHFA used quarterly data through the National Delinquency Survey to

identify and project trends by investor (including for FHA and VA mortgages). 

Mortgage performance data from Federal Reserve Bank of Atlanta – Forbearance outstanding

and non-forborne mortgages 30+ days past due by location and mortgagor type helped inform

our planning for program targeting and outreach.

In its HAF planning process, has the Participant obtained and reviewed quantitative data or studies regarding

which demographic segments in its jurisdiction have historically experienced discrimination in the housing or

housing finance market?

Yes

If yes, please list and, briefly describe each source of quantitative data.

VHFA has a long history of recognizing the critical importance of data-driven decisions when it

comes to using housing programs to reach undeserved communities. For this reason, the

Agency’s housing research department runs the Vermont Housing Data website (

www.housingdata.org) and conducts in depth housing needs assessments at the state, county and

local levels. We have conducted or reviewed the following studies to build our understanding of

the impact of discrimination in Vermont’s housing market. 

• Housing barriers for immigrants and refugees to Vermont 

• 2020 Vermont Housing Needs Assessment
Page 4 of 25

HAF Grantee Plan - HAFP-0040 -Agency of Commerce and Community Development - Extracted

 02/15/2022 18:41:55

o Race and Ethnicity (Fact Sheet, Report Chapter)

o Households with special needs and unique challenges (Fact Sheet Report Chapter) 

• Vermont Community Profiles 

o Race of householder 

o Tenure by race 

o Mortgage applications by race 

o Migrant workers 

o Homelessness

In its HAF planning process, has the Participant obtained quantitative data from utility providers or entities

charged with assessing and collecting property taxes or relied on quantitative data or studies to inform its

planning about how to target and best serve eligible homeowners at risk of displacement due to utility

arrearage or tax foreclosure?

Yes

If yes, please list and, briefly describe each source of quantitative data.

VHFA has used the most accurate sources available to plan and target HAF resources in need of

help with back property taxes or utility bills, as listed below: 

Experience from 2020-2021 Vermont Emergency Utility Assistance Program – In 2020 and 2021,

the Vermont Department of Public Service operated the Vermont COVID-19 Arrearage

Assistance Program which demonstrated the prevalence, level and types of needs for utility

assistance among Vermont homeowners harmed by the pandemic. 

Electric company reports – Two electric companies, Green Mountain Power and Vermont

Electric Cooperative, which cover most of Vermont reported delinquency rates and arrear

amounts that helped inform both the 2020-2021 program and plans for HAF utility assistance for

subsequent years. 

Survey of town tax officials – Results of a statewide survey VHFA conducted in July 2021 of

municipal governments provided key information for HAF program planning about the

prevalence and level of need among Vermont homeowners for help with back property taxes. 

Experience from 2020 Vermont Emergency Mortgage Assistance Program – In July through

November 2020 and again in May through June 2021, VHFA administered a CARES Act funded

Emergency Mortgage Assistance Program which provided property tax and mortgage assistance.

This experience demonstrated the prevalence, level and types of needs among Vermont

homeowners with mortgages for property tax assistance.

In the following text box, please list any source not listed above of quantitative information, including

sources of data on the performance of any of the Participant’s previously implemented programs, that the

Participant used to inform its HAF planning process, briefly describe how the data informed the Participant’s

planning.

Other sources consulted include the following:

Experience from 2020 Vermont Emergency Mortgage Assistance Program – In July through

November 2020 and again in May through June 2021, VHFA administered a CARES Act funded

Emergency Mortgage Assistance Program which demonstrated the prevalence, level and types of

needs among Vermont homeowners with mortgages harmed by the pandemic.
Page 5 of 25

HAF Grantee Plan - HAFP-0040 -Agency of Commerce and Community Development - Extracted

 02/15/2022 18:41:55

U.S. Census Bureau, American Community Survey – Estimates pertaining to tenure, mortgage

status, race, household income were used to estimate the scope of potential needs for

programmatic areas with gaps in evidence from other sources.

Manufactured Housing Loan Borrowers report from Consumer Financial Protection Bureau –

This detailed report provided state level information about the prevalence of chattel loans. This

helped us improve our estimates about the potential demand for help with this loan type.

Did the Participant communicate with mortgage servicers regarding the development of its program design?

Yes

Did the Participant communicate with other HAF participants regarding the development of its program

design?

Yes

How Has Community Engagement and Public Participation Informed the

Participant’s Planning?

Treasury will assess the extent to which a Participant’s assessment of homeowner needs has been informed

by and reflects input from organizations and individuals representing eligible homeowners, including any

opportunities for public participation in the development of the Participant’s plan. Treasury will pay

particular attention to the extent of the Participant’s engagement with populations that are the subject of

statutory targeting requirements.

Has the Participant requested and received input on its HAF planning process from providers of housing

counseling services or providers of legal assistance to homeowners facing foreclosure or displacement?

Yes

Provider information

If yes, please list such providers, including the providers’ address and website. Please indicate by checking

the appropriate box below if the provider’s primary purpose is to serve low- and moderate-income

households or to address the impacts of housing discrimination on one or more demographic groups in the

Participant’s jurisdiction.
Page 6 of 25

HAF Grantee Plan - HAFP-0040 -Agency of Commerce and Community Development - Extracted

 02/15/2022 18:41:55

Provider Name 

Provider Address 

Provider Website

Provider

Primarily

Serves

LMI

Households

Provider

Addresses

Impact of

Housing

Discrimination

Vermont Legal Aid

264 North Winooski Avenue, ,Burlington,Vermont 05401

https://www.vtlegalaid.org

Champlain Housing Trust

88 King Street ,Burlington,Vermont 05401

http://www.getahome.org

Neighborworks of Western Vermont

110 Marble Street ,West Rutland,Vermont 05777

http://www.nwwvt.org

Downstreet Housing & Community Development

22 Keith Ave Ste. 100 ,Barre,Vermont 05641

http://downstreet.org

Windham & Windsor Housing Trust

68 Birge Street ,Brattleboro,Vermont 05301

https://www.homemattershere.org

Opportunities Credit Union

25 Winooski Falls Way Suite 203,Winooski,Vermont 05404

https://www.oppsvt.org

Rural Edge

48 Elm Street PO Box 259,Lyndonville,Vermont 05851

https://ruraledge.org

Has the Participant requested and received input regarding its HAF planning process from community-based

organizations or organizations that serve potentially eligible homeowners?

Yes

Community Information

If yes, please list such organizations, including the providers’ address and website if available. Please

indicate by checking the appropriate box below if the provider’s primary purpose is to serve low- and

moderate-income households or to address the impacts of housing discrimination on one or more

demographic groups in the Participant’s jurisdiction.
Page 7 of 25

HAF Grantee Plan - HAFP-0040 -Agency of Commerce and Community Development - Extracted

 02/15/2022 18:41:55

Organization Name 

Organization Address 

Organization Website

Organization

Primarily

Serves LMI

Households

Provider

Addresses

Impact of

Housing

Discrimination

Champlain Valley Office of Economic Opportunity

255 So. Champlain St.PO Box 1603, Burlington, Vermont 05401

https://www.cvoeo.org/index.html

Association of Africans Living in Vermont (AALV)

20 Allen St3rd Floor, Burlington, Vermont 05401

http://aalv-vt.org

Rutland area NAACP

Rutland Area NAACPPO Box 311, Wallingford, Vermont 05773

http://naacprutland.org

The Housing Foundation, Inc.

P.O. Box 157, Montpelier, Vermont 05601

https://www.hfivt.org

People's United Bank

77 Pine street, Burlington, Vermont 05401

http://peoples.com

Burlington Community & Economic Development Office

City Hall149 Church Street, Burlington, Vermont 05401

https://www.burlingtonvt.gov/cedo

Central VT Habitat for Humanity

PO Box 837, Montpelier, Vermont 05602

https://www.centralvermonthabitat.org

Vermont Center for Independent Living

11 East Main Street, Montpelier, Vermont 05602

https://vcil.org

Vermont Housing & Conservation Board

58 East Main Street, Montpelier, Vermont 05602

https://www.vhcb.org

U.S. Committee for Refugees and Immigrants (USCRI-VT)

462 Hegeman Ave. #101, Colchester, Vermont 05446

https://refugees.org/uscri-vermont/

BROC Community Action

45 Union St., Rutland, Vermont 05701

https://www.broc.org/

Has the Participant consulted with localities or tribal governments (cities, counties, or rural communities) in

its jurisdiction regarding the needs of eligible homeowners in its jurisdiction?

Yes
Page 8 of 25

HAF Grantee Plan - HAFP-0040 -Agency of Commerce and Community Development - Extracted

 02/15/2022 18:41:55

Has the Participant provided an opportunity for public input regarding its HAF Plan through public hearings

or published materials?

Yes

If yes, please indicate whether a proposed or draft plan was published, please describe where details about the

comment solicitation were posted, for how long, in what languages, and whether any efforts were made to

make the posting accessible to persons with disabilities or individuals without reliable internet access.

This HAF Plan was informed by four virtual public meetings (with phone access) held June 1,

June 3, June 22 and August 19. VHFA published a Vermont HAF News web page on May 21,

2021 containing the latest information about the program, public meetings and instructions for

submitting comments and questions. On June 30, VHFA released a draft program description

and shared program income limits. On August 13, VHFA published a narrative draft HAF plan.

To ensure access to people with low English proficiency, all web-based outreach was

accompanied by an opportunity to request translation. According to the Census Bureau’s 2019

American Community Survey, there are an estimated 2,380 limited English-speaking households

in Vermont (0.9%).

To adequately address the needs of underserved communities in Vermont’s HAF plan, VHFA

sought feedback from a wide network of community-based and statewide organizations. All four

public meetings were publicized on the VHFA News blog and social media pages which reach

1,000s of subscribers and followers. In addition, VHFA directly invited over 60 key stakeholders

directly from across the state, encouraging them to participate in the meetings and/or provide

written comment. These include: every HUD-approved homeownership center; the state’s

network of housing nonprofits, including all five Neighborworks of America partner

organizations; state and federal housing agencies; each legal aid group; every town’s manager

and clerk; banks and credit unions; utility companies; the local United Ways; homebuilding

associations; agencies serving seniors and people with disabilities, including our state Center for

Independent Living; and organizations representing minority Vermonters, including refugee

resettlement groups and local NAACP chapters.

Please see HAF-Grantee-Plan-Template-Response PDF attached for further detail due to

character constraints.

How Will the Participant Continue to Assess the Needs of Eligible

Homeowners?

Treasury anticipates that an ongoing process of assessing the needs of eligible homeowners will help address

the needs of potentially eligible homeowners as economic conditions change over time.

Does the Participant plan to update its assessment of community needs within the next year to determine

whether its HAF program design should be updated to address changing needs of potentially eligible

homeowners?

Yes

What additional data would be helpful to the Participant as it seeks to assess homeowner needs over time?

Quarterly data about rate of serious loan delinquency/foreclosure for Vermont homeowners at

or below 100% AMI in the following break-outs:
Page 9 of 25

HAF Grantee Plan - HAFP-0040 -Agency of Commerce and Community Development - Extracted

 02/15/2022 18:41:55

• county

• servicer

• investor type (including FHA, VA, RD, private)

Quarterly data about rate of loan delinquency by loan type among Vermont homeowners

• Reverse mortgages

• Chattel loans

• Other

Quarterly rate of utility delinquencies among Vermont homeowners at or below 100% AMI

Quarterly rate of association fee delinquencies among Vermont homeowners at or below 100%

AMI

Quarterly rate of property tax delinquency among Vermont homeowners who do not escrow

these with their mortgage and have incomes at or below 100% AMI

Every 12 months, we will analyze and report on Vermont’s HAF program activity relative to

initial projections and performance goals. Specifically, we will compare the HAF assistance

provided to Vermont homeowners with our initial demand projections to identify areas in which

homeowner needs may have shifted. By confirming HAF usage trends with broader quantitative

data sets available through mortgage servicers, the National Delinquency Survey, the Federal

Reserve Bank of Atlanta, Vermont’s largest utility providers, and the Census Bureau, we will

propose any changes warranted to our HAF plan. For example, if the demand for utility

assistance through Vermont’s HAF program during the first year falls short of initial

projections, we will explore why this is occurring and if we confirm that needs have declined, we

may submit a HAF plan change request to offer an additional type of assistance not in our

original plan, such as help with home repairs.
Page 10 of 25

HAF Grantee Plan - HAFP-0040 -Agency of Commerce and Community Development - Extracted

 02/15/2022 18:41:55

Program Design

What are the Program Design Elements Through Which the Participant Will

Deliver HAF Assistance to Eligible Homeowners?

A program design element is a specific activity or program, which is consistent with a qualified expense

category, under which a Participant will disburse HAF funds in accordance with the HAF Plan. Please note

that multiple program design elements may fit under a single qualified expense category; for example, a

mortgage assistance program that has different terms for federally backed mortgages and manufactured-home

mortgages may constitute two separate program design elements, for which case the Participant provides a

separate term sheet or other description for each program design element. 

HAF participants must have at least one program design element intended to reduce mortgage delinquency

among targeted populations. Treasury encourages HAF participants to consider program design elements that

address homeownership preservation for targeted populations in areas where there is a sustained trend of

increasing property taxes or utility costs, including for households that do not have mortgages.

Please identify each qualified expense category in which the Participant will offer a program design element

by checking the boxes below.

mortgage payment assistance 

 mortgage principal reduction, including with respect to a second mortgage provided by a nonprofit

or government entity 

 payment assistance for homeowner’s utilities, including electric, gas, home energy, and water 

 payment assistance for homeowner’s insurance, flood insurance, and mortgage insurance 

 payment assistance for delinquent property taxes to prevent homeowner tax foreclosures 

 payment assistance for down payment assistance loans provided by nonprofit or government

entities 

 financial assistance to allow a homeowner to reinstate a mortgage or to pay other housing-related

costs related to a period of forbearance, delinquency, or default 

facilitating mortgage interest rate reductions 

 payment assistance for homeowner’s internet service, including broadband internet access service,

as defined in 47 CFR 8.1(b) 

 payment assistance for homeowner’s association fees or liens, condominium association fees, or

common charges 

 measures to prevent homeowner displacement, such as home repairs to maintain the habitability of

a home or assistance to enable households to receive clear title to their properties 
Page 11 of 25

HAF Grantee Plan - HAFP-0040 -Agency of Commerce and Community Development - Extracted

 02/15/2022 18:41:55

For each program design element that the Participant will offer, the Participant is required to upload a term

sheet or other description, that, at a minimum, provides the following information regarding that program

design element. Term sheets for all of Participant’s HAF programs may be uploaded together as one

document.

Title Upload Date

VHFA HAF Plan Narrative 12/2/2021 5:01 PM

HAF-Grantee-Plan-Template-Responses 12/2/2021 5:02 PM

HAF-Plan-Treasury-Feedback-Response 12/2/2021 5:02 PM

HAF Program Term Sheets 12/2/2021 5:01 PM

A HAF participant may elect to revise its HAF Plan over time to add or subtract program design elements.

Does the Participant anticipate adding additional program design elements to this HAF Plan within one year

of this submission?

No

Treasury has provided sample term sheets to assist HAF participants in developing their HAF plans.

Participants may use these sample term sheets, in whole or in part, as part of their submission. To the extent

the Participant intends to structure the program differently with respect to significant program terms

described in the Sample Term Sheets, Treasury will, in the course of its review of the HAF Plan, request a

justification for how the alternate approach will further the objectives of the HAF, including targeting and

prioritization requirements. In the chart below, the HAF Participant may provide a justification for significant

deviations from the terms described in the sample term sheets upon initial submittal. (optional for initial

submission)
Page 12 of 25

HAF Grantee Plan - HAFP-0040 -Agency of Commerce and Community Development - Extracted

 02/15/2022 18:41:55

Program

Design

Element

Deviation from sample

terms Justification

Mortgage

Assistance

Program

This is based on the

Mortgage Reinstatement

Program Template with

some deviations. We have

not specifically stated that

funds are only to

supplement other loss

mitigation options. We

have not required that

applicants state they have

the ability to resume

payments after

reinstatement. We have not

required that reverse

mortgage borrowers enter

a payment plan.

These deviations reflect VHFA’s experience with its recent

CARES Act-funded Mortgage Assistance Program. Servicers

with mortgages that are in forbearance or have been subject to

loss mitigation consider the loans to be current and do not

indicate that any amount is due, so no payment is made.

Requiring the commencement of loss mitigation in every case

would create delay and confusion for the applicants. Mitigation

processes may result in partial claim liens/soft seconds that

reduce equity for populations that are already disparately

impacted when it comes to homeownership and wealth

building. Requiring applicants to certify that they will have the

ability to resume payments could result in applicants being

unwilling to apply for fear that if they do not remain current

that the assistance might be “clawed back”.

Property

Charge

Assistance

Program

We have not included

insurance premiums

outside of amounts

included in mortgage

escrows as part of the

Mortgage Assistance

Program.

Given the expected needs and the funding available we focused

on those charges that could result in a lien on the property such

as property taxes, homeowner association fees and other

charges, and necessary utilities.

Maximum

Benefit

Our maximum benefit is a

cap to cover all 3

programs.

Provides flexibility in dealing with individual circumstances,

especially where an applicant may have allowed themselves to

get behind on one set of costs in order to stay current on

another. Programs are ranked in priority so if an applicant’s

total need exceeds the cap, we first look to the mortgage, then

property taxes, then other common charges, then utilities.

Documentation of Homeowner Income

Homeowners are eligible to receive amounts allocated to a HAF participant under the HAF only if they have

incomes equal to or less than 150% of the area median income or 100% of the median income for the United

States, whichever is greater. In addition, not less than 60% of amounts made available to each HAF

participant must be used for qualified expenses that assist homeowners having incomes equal to or less than

100% of the area median income or equal to or less than 100% of the median income for the United States,

whichever is greater. The HAF guidance describes permissible ways for HAF participants to determine

homeowner income.

Under the HAF guidance, one permissible approach for determining income is for (1) the household to

provide a written attestation as to household income and (2) the HAF participant to use a reasonable

fact-specific proxy for household income, such as reliance on data regarding average incomes in the

household’s geographic area. Will the Participant allow income to be determined in this way?

Yes
Page 13 of 25

HAF Grantee Plan - HAFP-0040 -Agency of Commerce and Community Development - Extracted

 02/15/2022 18:41:55

If yes, please describe the fact-specific proxy or proxies to be used for the income determination.

VHFA may rely on fact-based proxies such as whether the homeowner can provide proof of

current receipt of benefits under a federal means-tested program which requires income to be at

or below that required income for an eligible homeowner under HAF (such as Supplemental

Nutritional Assistance Program/SNAP (3SquaresVT) or Medicaid) or the location of the

residence in a census tract with one of the following designations:

a. FHFA Duty to Serve designations of Areas of Concentrated Poverty

b. HUD designations of Racial and/or Ethnic Areas of Concentrated Poverty

c. FFIEC designations of distressed, underserved, poverty, remote rural and/or unemployment

d. HUD designations of Qualified Census Tracts for use in the Low-Income Housing Tax Credit

program

e. Other fact-based proxy eligibilities may be developed as data becomes available.

Under the HAF guidance, HAF participants may provide waivers or exceptions to this documentation

requirement as reasonably necessary to accommodate extenuating circumstances, such as disabilities,

practical challenges related to the pandemic, or a lack of technological access by homeowners; in these cases,

the HAF participant is still responsible for making the required determination regarding household income

and documenting that determination. Will the Participant allow applicants to request such waivers or

exceptions?

Yes

Eligible Mortgage Types

Please indicate which of the following mortgage types are eligible to be assisted under one or more of the

Participant’s program design elements.

 First Mortgages 

 Reverse Mortgages (Home Equity Conversion Mortgages, Single-Purposes Reverse Mortgages, or

Proprietary Reverse Mortgages) 

 Contracts for Deed or Land Contract (if it is a credit transaction secured by a consensual security

interest in a dwelling) 

 Second Mortgages 

 Loans Secured by Manufactured Housing (secured by real estate or dwelling) 

If the Participant excludes any of the forgoing mortgage types from one or more program design elements,

explain the exclusion.

N/A

How Will the Participant Target HAF Resources Consistent with Statutory

Requirements? 

The Participant must describe how it will target HAF resources in accordance with the HAF guidance.

Targeting strategies are affirmative efforts to inform, encourage the participation of, and facilitate access to

resources for targeted households, including by offering multiple intake formats, engaging with nonprofit
Page 14 of 25

HAF Grantee Plan - HAFP-0040 -Agency of Commerce and Community Development - Extracted

 02/15/2022 18:41:55

organizations (e.g., housing counselors or legal services organizations) to provide additional pathways into

the program, and providing community outreach, partnerships with housing counseling agencies or legal aid

organizations, or other educational services that are aligned with the HAF participant’s program design, in a

manner that is culturally and linguistically relevant to the targeted communities.

Defining Socially Disadvantaged Individual

Please describe the process the Participant will use to determine whether a homeowner is a “socially

disadvantaged individual” as defined in the HAF guidance.

Participants will be asked whether they or a member of their household is Black, Indigenous,

Asian American/Pacific Islander, Non-white Hispanic, South Asian or if they or a member of

their household has limited English proficiency. Vermont has no majority-minority census tracts

or persistent poverty counties. Vermont is not and does not encompass a US territory, Indian

reservation or Hawaiian Home Land.

Public Communications

Will the Participant engage in a public communications campaign to raise awareness among targeted

populations about the availability of HAF resources, in media such as television, newspapers, online media,

or social media?

Yes

If yes, please indicate whether the public communications campaign will include communications that

primarily target the following populations:

 Homeowners earning less than 100% of area median income 

 member of a group that has been subjected to racial or ethnic prejudice or cultural bias within

American society; 

 resident of a majority-minority Census tract; (3) 

 resident of a U.S. territory, Indian reservation, or Hawaiian Home Land 

 homeowners in persistent poverty counties; 

 individual with limited English proficiency 

Please indicate in which languages, in addition to English, public communications to targeted populations

will be undertaken:

Spanish; Chinese; Vietnamese; Arabic; Other

Please list any other languages.

Somali, Swahili, French, Burmese, Nepali, Bosnian

Outreach
Page 15 of 25

HAF Grantee Plan - HAFP-0040 -Agency of Commerce and Community Development - Extracted

 02/15/2022 18:41:55

Will the Participant engage in outreach through partnerships with organizations that focus primarily on

serving homeowners earning incomes below 100% of area median income or socially disadvantaged

individuals and that have the capacity to engage targeted communities in a culturally and linguistically

relevant manner to encourage the submission of applications for HAF resources from targeted populations?

Yes

If yes, please indicate whether the community outreach efforts will include partnerships with organizations

that primarily target the following populations:

 member of a group that has been subjected to racial or ethnic prejudice or cultural bias within

American society; 

 resident of a majority-minority Census tract; (3) individual with limited English proficiency; 

 resident of a U.S. territory, Indian reservation, or Hawaiian Home Land;

 homeowners that reside in persistent poverty counties; 

 individual with limited English proficiency. 

Please list any other languages.

Somali, Swahili, French, Burmese, Nepali, Bosnian

Housing Counseling and Legal Services

Will the Participant facilitate access for eligible households to housing counseling or legal services?

Yes

If yes, please identify below the providers of housing counseling or legal services that have indicated to the

Participant that they are willing and able to support homeowners receiving assistance under the Participant’s

HAF programs. 
Page 16 of 25

HAF Grantee Plan - HAFP-0040 -Agency of Commerce and Community Development - Extracted

 02/15/2022 18:41:55

Provider Name 

Provider Address 

Provider Website

Provider

Primarily

Serves

LMI

Households

Provider

Addresses

Impact of

Housing

Discrimination

Vermont Legal Aid

264 North Winooski Avenue , Burlington, Vermont 05401

https://www.vtlegalaid.org

Champlain Housing Trust

88 King Street , Burlington, Vermont 05401

https://www.getahome.org

Rural Edge

48 Elm Street PO Box 259, Lyndonville, Vermont 05851

https://ruraledge.org

Neighborworks of Western Vermont

110 Marble Street , West Rutland, Vermont 05777

https://www.nwwvt.org

Downstreet Housing & Community Development

22 Keith Ave, Ste. 100 , Barre, Vermont 05641

https://downstreet.org

Windham & Windsor Housing Trust

68 Birge Street , Brattleboro, Vermont 05301

https://www.homemattershere.org/

Opportunities Credit Union

25 Winooski Falls Way Suite 203, Winooski, Vermont 05404

https://www.oppsvt.org/

Targeting specific groups of homeowners

Will the Participant conduct outreach specifically tailored to target potentially eligible households that:

 have mortgages or mortgage assistance contracts held or backed by the Participant? 

 have mortgages backed by any of the following agencies: Federal Housing Administration;

Department of Veterans Affairs; U.S. Department of Agriculture? 

 have privately held mortgages? 

What Efforts will be Made to Address Barriers to HAF Program Participation for

Potentially Eligible Homeowners, Including Those with Limited English

Proficiency or Who are Disabled?

Targeted outreach may be needed to reach homeowners who are likely to experience barriers to access,

including persons with limited English proficiency and those with disabilities.
Page 17 of 25

HAF Grantee Plan - HAFP-0040 -Agency of Commerce and Community Development - Extracted

 02/15/2022 18:41:55

Indicate all of the languages, in addition to English, in which the Participant’s HAF application and other

program documents will be made available.

Spanish; Chinese; Vietnamese; Arabic; Other

Please list any other languages.

Somali, Swahili, French, Burmese, Nepali, Bosnian

Will the Participant’s HAF applications and other program documents be provided in forms that are

accessible to persons with disabilities?

Yes
Page 18 of 25

HAF Grantee Plan - HAFP-0040 -Agency of Commerce and Community Development - Extracted

 02/15/2022 18:41:55

Performance Goals

Treasury will consider the goals and benchmarks the Participant proposes to use to measure the effectiveness

of its programs, including whether those goals address the homeowner needs identified by the Participant, the

extent to which the goals are disaggregated by key homeowner characteristics as appropriate for the

jurisdiction, and whether they include a goal focused on reducing mortgage delinquency.

Please describe Participant’s goals and benchmarks for each of its programs with the following program

design elements.

Program

Design

Element

Metric of Success Goal

Mortgage

Reinstatement Number of mortgage loans

reinstated

Annual change in mortgage loans reinstated is equal

to or exceeds the annual change in the total number of

Vermont mortgages with delinquencies.

Payment

Assistance for

HOA fees or

liens

Number of households whose

homeowner association fees or

liens, condominium association

fees or common charges are

brought current.

Annual change in households with fees brought

current is within 5 points of the annual change in the

total number of Vermont mortgages with

delinquencies.

Payment

Assistance for

Homeowners

Utilities

Number of households whose

utility bills are brought current

Annual change in number of households whose utility

bills are brought current is within 10 points of the

annual change in Vermont Census Bureau pulse

survey respondents who said they had trouble paying

energy bills.

Payment

Assistance for

Delinquent

Property

Taxes

Number of households whose

delinquent property taxes are

brought current.

Annual change in households with taxes brought

current is within 5 points of the annual change in the

total number of Vermont mortgages with

delinquencies.
Page 19 of 25

HAF Grantee Plan - HAFP-0040 -Agency of Commerce and Community Development - Extracted

 02/15/2022 18:41:55

Readiness

Staffing, Systems and Contractors 

Treasury seeks information regarding the Participant’s organizational capacity to implement its HAF Plan.

Does the Participant anticipate needing to hire additional staff to implement this HAF Plan?

Yes

Does the Participant anticipate significant information technology system upgrades to implement this HAF

Plan?

Yes

Does the Participant have policies or procedures that govern the implementation of each HAF program

design element described in this HAF Plan?

No

If no, is a policy and procedure in development for each HAF program design element described in this HAF

Plan?

Yes

Will the Participant use HAF funds to assist eligible households through a program that was operational

before the Participant first received HAF funds?

No

Will the Participant use any third-party contractor or partner to conduct program administration (such as

reviewing applications, determining eligibility, processing payments, conducting reporting, and reviewing

compliance) for some or all of the Participant’s HAF programs?

Yes

If yes, has the Participant entered into all necessary arrangements with all of the third-party contractors or

partners that will conduct program administration?

Yes

Use of Initial Payment

If the Participant has already received any HAF funds from Treasury, provide the following information

about the use of such funds as of June 30, 2021.
Page 20 of 25

HAF Grantee Plan - HAFP-0040 -Agency of Commerce and Community Development - Extracted

 02/15/2022 18:41:55

What amount of the HAF funds that the Participant has received been disbursed to eligible homeowners?

$0.00

Has the Participant begun accepting applications from homeowners for any HAF-funded programs?

No

How much of the HAF funds that the Participant has received been obligated?

$1,057,315.00

Provide a brief description of how the Participant has used the HAF funds it has received.

So far, the 10% payment of HAF funds has been used for payments to our vendor for

development of the application portal and for development of systems and processes to manage

the program and for staff planning and program development. As of this time, $1,057,315 has

been spent for these purposes. Because VHFA had just completed a round of CARES Act funded

mortgage assistance which closed in June 2021, no pilot program was offered using Homeowner

Assistance Fund money to allow for the Agency to focus on developing the Homeowner

Assistance Program. Additionally, the state used CARES Act funds to provide well over $15

million in utility arrearage funding to households and businesses through a program that was

open through October 2021.
Page 21 of 25

HAF Grantee Plan - HAFP-0040 -Agency of Commerce and Community Development - Extracted

 02/15/2022 18:41:55

Budget

Budgeting of HAF Funds by Program Design Element 

Specify the amounts of HAF funds that the Participant proposes to allocate to each of the following program

design elements, if offered:

Measure Amount

Mortgage Payment Assistance $0.00

Mortgage Principal Reduction $0.00

Payment Assistance for Homeowner’s Internet Service $0.00

Payment Assistance for HOA fees or liens $4,539,078.00

Payment Assistance for Delinquent Property Taxes $7,168,590.00

Mortgage Reinstatement $18,827,692.00

Facilitate Mortgage Interest Rate Reduction $0.00

Payment Assistance for Homeowner’s Insurance $0.00

Payment Assistance for Down Payment Assist. Loans $0.00

Payment Assistance for Homeowners Utilities $10,581,457.00

Other measures to prevent homeowner displacement

Measure Amount

N/A $0.00

Displacement Prevention Sub-Total $41,116,817.00

Counseling or Legal Services

The Participant may allocate up to 5% of its HAF funds for counseling or educational efforts by housing

counseling agencies approved by the Department of Housing and Urban Development or a tribal government,

or legal services, target to households eligible to be served with funding from the HAF related to foreclosure

prevention or displacement.
Page 22 of 25

HAF Grantee Plan - HAFP-0040 -Agency of Commerce and Community Development - Extracted

 02/15/2022 18:41:55

Specify the Participant’s allocations for the following Amount

Counseling or Educational Services $560,000.00

Legal Services $821,000.00

Services Sub-Total $1,381,000.00

Reimbursement of Funds Expended After January 21, 2020

As described in the HAF guidance, HAF funds may be used for reimbursement of certain expenses between

January 21, 2020 and the date when the first HAF funds are disbursed by the HAF participant under the HAF

for a qualified expense (with certain limitations, as set forth in the HAF guidance).

Type of Expense Amount

N/A $0.00

Reimbursement Sub-Total $0.00

Allocation of Administrative Expenses

Type of Expense Amount

FAMS License and Fees $1,001,000.00

Cloud hosting and storage $330,000.00

System Support $1,245,000.00

Call center and operations $2,109,201.00

Program management $2,814,799.00

Administrative Expenses Sub-Total $7,500,000.00

Total Plan Requested Amount $49,997,817.00

Amount Requested Confirmation:

Yes
Page 23 of 25

HAF Grantee Plan - HAFP-0040 -Agency of Commerce and Community Development - Extracted

 02/15/2022 18:41:55

Contacts

Please identify up to three contacts for the Participant- a primary contact, a designated point of contact for

reporting, and an additional contact.

Primary Contact

Name: Maura Collins, Executive Director

Agency/Office: Vermont Housing Finance Agency

Email: mcollins@vhfa.org

Phone Number: 8026523434

Reporting Contact

Name: Naomi Cunningham, Grants Management Specialist

Agency/Office: Vermont Department of Housing and Community Development

Email: naomi.cunningham@vermont.gov

Phone Number: 8022492689

Additional Contact

Name: Maxwell Krieger, General Counsel

Agency/Office: Vermont Department of Housing and Community Development

Email: maxwell.krieger@vermont.gov

Phone Number: 8025223132

Proprietary or Otherwise Non-Public Information

Does your plan submission include any information or materials that are proprietary or otherwise non-public?

No

If "Yes," please indicate which information or materials are proprietary or otherwise non-public.
Page 24 of 25

HAF Grantee Plan - HAFP-0040 -Agency of Commerce and Community Development - Extracted

 02/15/2022 18:41:55

Title VI Assurances

You must provide on behalf of the HAF Participant assurances that the HAF Participant will comply with

Title VI of Civil Rights Act of 1964. Please download the assurances, then review, sign, and upload the

signed copy to this page before submitting the HAF Plan.

Title Upload Date

Signed HAF-Title_VI_Assurance 12/2/2021 5:10 PM
Page 25 of 25

HAF Grantee Plan - HAFP-0040 -Agency of Commerce and Community Development - Extracted

 02/15/2022 18:41:55

Official Certification

I (the undersigned) certify that the information provided in the HAF submission is accurate and complete

after reasonable inquiry of people, systems, and other information available to the HAF Participant. The HAF

participant and I acknowledge that any materially false, fictitious, or fraudulent statement or representation

(or concealment or omission of material fact) in this submission may be the subject of criminal prosecution

under the False Statements Accountability Act of 1996, as amended, 18 U.S.C. § 1001 and also may subject

me and HAF Participant to civil penalties and/or administrative remedies for false claims or otherwise,

(including 31 U.S.C. §3729 et seq.). I am an authorized representative of HAF Participant with authority to

make the above certifications and representations on behalf of the HAF Participant.

Name of HAF Participant:

Agency of Commerce and Community Development

Name and Title of Certifying Official

Name: Lindsay Kurrle

Title: Secretary, Vermont Agency of Commerce and Community Development

Telephone: 8028283080

Email: lindsay.kurrle@vermont.gov