1
1

Contents

Introduction.............................................................................................................................................2

Homeowner’sAssistance FundLandscapeAnalysis&ProposalforDefiningSocialDisadvantage....................................3

Mortgage Assistance Need in Tennessee ...................................................................................................3

Mortgage Delinquency Rates...................................................................................................................3

Forbearance Rates..............................................................................................................................4

Proposed Definition of Social Disadvantage...............................................................................................6

Individual-Level Measures...................................................................................................................6

Census Tract-Level Measures...............................................................................................................7

County-Level Measures.......................................................................................................................8

General Household, Economic, and Income Characteristics of Tennessee........................................................9

Households and Homeowners..............................................................................................................9

Employment in the Most COVID-19 Impacted Sectorsin Tennessee ...........................................................9

Income and Poverty.......................................................................................................................... 11

Homeowner Needs and Minority Disparities in Tennessee ............................................................................ 13

Community Engagement and Outreach...................................................................................................... 15

Program Design ...................................................................................................................................... 16

TNHAF Budget........................................................................................................................................ 27

Program Goals........................................................................................................................................ 28

Readiness............................................................................................................................................... 29
2

TNHAF

Tennessee Homeowner Assistance Plan

Introduction

The Homeowners Assistance Fund was established under Section 3206 of The American Rescue Plan Act of 2021. The combined 

assistance provided under the HAF program is $9.9 billion to be administered to states, territories and tribal governments. Of 

that amount the state of Tennessee was allocated $168,239,035. With approval provided by the office of the Governor, the 

Tennessee Housing Development Agency (THDA) will administer the HAF funds to those eligible homeowners experiencing a 

financial hardship related to the Covid-19 pandemic. 

On April 14, 2021 and August 2, 2021 the US Department of Treasury provided the Homeowner Assistance Fund (HAF) Guidance. 

THDA staff will be following this guidance in preparing the HAF program proposal, the TNHAF Plan, to be submitted to the U.S. 

Department of Treasury for approval by August 21, 2021. The TNHAF plan will be made available to mitigate financial hardships

associated with the coronavirus pandemic (Covid-19) to assist in preventing mortgage delinquencies, foreclosures, defaults and 

other related housing expenses. Eligibility will be determined based on the TNHAF Program Guidelines.

The Covid -19 pandemic has produced abrupt shifts in Tennessee’ economic and housing landscape. As the economic crisis 

unfolded, the federal government passed the CARES Act in late March 2020, classifying the option of forbearancefor American 

homeowners. With the onset of the pandemic unemployment increased dramatically reaching a high of 15.8% in April 2020.

With many of Tennessee’s household experiencing job loss and/or increased expenses families struggled to make their mortgage 

payments and found themselves severely delinquent. Although the unemployment numbers have significantly improved many 

of the recent hires/jobs have been restructured as contract labor. This could cause additional financial hardship on the more 

fragile income population of workers going forward and adds to the risk of ongoing delinquency and default.

Within a few short months in 2020 the 90+ day mortgage delinquency increased by 250%, a direct result of the rise in 

unemployment(3). With the continued extensions of the foreclosure moratorium and forbearance options homeowners across 

the country descended into deeper delinquency. Furthermore it is unclear whether mortgage delinquency rates will show a drop 

commensurate with the improving employment landscape. The slow exists seen in those homeowners leaving forbearance 

suggest that leaving forbearance is difficult with most homeowners now in forbearance for over 12 months. The expectation of 

delinquency due to forbearance is estimated at $90 billion dollars nationallyand based on our research data in Tennessee, there 

may be up to 9500 delinquent mortgage loans with borrowers under 100% AMI that could need assistance to bring their 

mortgage loans current. 
3

Homeowner’s Assistance Fund Landscape Analysis &Proposal for Defining Social

Disadvantage

August 11, 2021

Mortgage Assistance Need in Tennessee

Mortgage Delinquency Rates

The Treasury Department’s guidance indicates that no less than 60% of the assistance should be for homeowners with

incomes equal to or less than 100% of the area median income (AMI) for either Tennessee or the median income of the

United States, whichever is greater.Weprojectan estimateof approximately 9,500severely delinquent (90+days)loans

for homeowners at or below 100% AMI across the state of Tennessee would be eligible under this provision.i Figure 1

belowshowsthedistribution ofserious delinquency rates acrossthe state.

Figure 1: Percent ofseriously delinquent loans by censustract

This estimate is downwardly biased because borrowers who are 30+ and 60+ days delinquent are also eligible to receive

assistance. Furthermore, dueto data limitations,wearenot ableto calculatethepercent of homeownersin Tennesseewho

are below the U.S. median income, but we estimate that the vast majority of areas in the state have lower AMIs than the

median income of the nation. This estimate is also likely upwardly biased by thefact that delinquent borrowers must

demonstrate COVID-19 related financial hardships in order to receive assistance and it is likely that some portion of

delinquentborrowersfaced hardship unrelated to thepandemic.

Prior research conducted by Research and Planning indicated that overall mortgage delinquency (30+ days) as of February

2021 is at6.1%in Tennesseeshrinking froma pandemicpeak of 7.7%.ii Thedelinquencyrates forFHAborrowers areworse,

at approximately 16%.iii

Table 1: Mortgage delinquency rates across Tennessee

DataSource Feb.2021 Covid-19 Peak

MortgageDelinquencyRate Black Knight 6.1% 7.7%

SevereMortgageDelinquencyRate

(90+days delinquent)

CoreLogic THDAunableto discloserawdata values

FHA-SpecificDelinquency Rate HUDNeighborhood Watch 15.8% 15.6%
4

Forbearance Rates

In addition to delinquency rates, we determine that mortgage assistance may be most needed in areas that have higher

rates in forbearance. The data are sourced from the Atlanta Federal Reserve, whose calculations used Black Knight’s

McDash Flash daily mortgage performance data (available with a two-day lag) with U.S. Census Bureau 2017 FIPS Codes.

Race data is based on 2014-2018 American Community Survey (Source: IPUMS NHGIS, University of Minnesota,

www.nhgis.org).Wedenotethezip codes with thegreatestnumberof homesinforbearanceas of March2021in Figure2

below.

Figure 2: Number of homes in forbearance by zip code *

A sample of this forbearance data is presented in Tables 2a and 2b below. In Table 2a, the ten zip codes with the highest

percentof homes inforbearancearelisted. Thesezip codes vary in therangeofthepercentofminoritiesinthearea.

Table 2a: Top 10 zip codeswith highest forbearance rates(SampleofAtlantaFed Reservedata)

County Zip Code

% Minority

Population % in Forbearance % inDelinquency

GibsonCounty 38330 17.68 11.69 5.19

Shelby County 38115 93.72 11.66 8.87

GraingerCounty 37811 2.59 10 6.15

Hamilton County 37406 80.36 9.8 10.36

Shelby County 38141 94.44 9.51 8.5

Union County 37866 9.9 9.21 1.32

Shelby County 38125 86.78 8.98 7.78

Shelby County 38128 89.66 8.53 9.47

Hamilton County 37373 2.94 8.33 3.79

Carter County 37687 2.66 8.33 5.56

Source: The data are sourced from the Atlanta Federal Reserve, whose calculations used Black Knight’s McDash Flash daily mortgage performance data

(available with a two-day lag) with U.S. Census Bureau 2017 FIPS Codes. Race data is based on 2014-2018 American Community Survey (Source: IPUMS

NHGIS, University of Minnesota, www.nhgis.org).
5

In Table 2b, only zip codes that are majority-minority, e.g. comprised of at least 50% minorities, are considered. The

majority of these zip codes are in Shelby County. The association between forbearance and percent minority share is

moderate suggesting that areas with more minority populations are more likely to have homes in forbearance. The

association between delinquency and forbearanceis even stronger. These resultsindicate thatfocusingefforts on areas

with higher shares of minority populations will ensure that assistance is targeted towards areas with more homes in

mortgage forbearance.

Table 2b: Top 10 zip codeswith highestforbearanceratesin majority –minority zip codes(SampleofAtlantaFed

Reserve data)

County Zip Code

% Minority

Population % in Forbearance % inDelinquency

Shelby County 38115 93.72 11.66 8.87

Hamilton County 37406 80.36 9.8 10.36

Shelby County 38141 94.44 9.51 8.5

Shelby County 38125 86.78 8.98 7.78

Shelby County 38128 89.66 8.53 9.47

Davidson County 37218 79.89 7.9 5.89

Shelby County 38118 93.73 7.81 13.12

Shelby County 38116 97.06 7.42 10.7

Shelby County 38114 95.07 7.4 11.99

Shelby County 38016 59.89 7.38 4.54

Source: The data are sourced from the Atlanta Federal Reserve, whose calculations used Black Knight’s McDash Flash daily mortgage performance data

(available with a two-day lag) with U.S. Census Bureau 2017 FIPS Codes. Race data is based on 2014-2018 American Community Survey (Source: IPUMS

NHGIS, University of Minnesota, www.nhgis.org).
6

Proposed Definition of Social Disadvantage

Per guidancefromtheTreasuryDepartment, any amountnotmadeavailableto homeowners ator below100%AMI should

be prioritized for individuals who are “socially disadvantaged,” who can have incomes up to 150% AMI.iv Using guidance

from procedures set forth at 13 CFR 124.103(c) or (d),v we recommend defining social disadvantage with the following

process:

1) First, ifan individual identifies as a member of aminority raceor ethnicity,then they aredeemed socially

disadvantaged.

2) If the individual’s race and ethnic status is undetermined, then THDA will check to determine whether the

individualaccessedlanguage assistanceto determineifthey arelimited inEnglish proficiency. Ifso,then the

individualis deemed sociallydisadvantaged.

3) If the individual’s status is still undetermined, THDA will determine the individual’s census tract. If the

individual lives in a tract that is majority-minority or has a poverty level of above 20%, the individual may be

deemed socially disadvantaged.

4) Finally, if not applicableatthetract-level,then theindividual’s county ofresidenceis onethathas been

deemed to have“persistentpoverty,” then theindividualmay bedeemed socially disadvantaged.

Prior administration of the Hardest Hit Fund (HHF) serves as an indicator for projections of usage for CHAF. While the

circumstances and parameters associated with HHF are markedly different than those of CHAF, we find that of the 13,000

Tennesseans assisted by HHF, 38% were non-white and 4% were Hispanic. Because HHF was used to both assist

homeowners with mortgages as well as offer mortgages, unlike CHAF, which is limited to solely mortgage assistance,

limiting social disadvantage toonly raceand ethnicitymight not be sufficient. Furthermore,to ensurethatthefundsfrom

CHAF are prioritized for individuals and areas at either 100% AMI or below or individuals that are likely to face

discriminationor bias duetheirmembership ina group,werecommend considering other factors ofsocial disadvantage.

Individual-Level Measures

Table3 belowoutlinestheindividual-level factors,theirrepresentationinthestate, andtheintended method of collecting

this data. Individuals that identify as members of the groups below in their application or ones considered to be limited

English proficientby THDA areconsidered socially disadvantaged.

Table 3: Proposed individual-levelfactors ofsocial disadvantage & statisticsin Tennessee

Count

State

Percentage

DataCollection

Method

Race&EthnicityofOwner-Occupied Households 1,722,247

American Indian/AlaskaNative 4,102 0.2% Application

Asian 21,258 1.2% Application

Black orAfricanAmerican 181,642 10.5% Application

NativeHawaiian/Pacific Islander 300 0.0% Application

White 1,487,715 86.4% Application

SomeOther (and two or more) 27,230 1.6% Application

Hispanicor Latino (of anyrace) 38,418 2.2% Application

Speaks English“Less thanWell” (Age5+) 188,706 2.9% THDA tracks whether

individual utilized

languageassistancein

application

Source: American Community Survey (ACS), Five-Year Estimates, 2015-2019
7

Census Tract-Level Measures

Tables 4a and 4b outline the tract-level factors to consider if individual-level factors are undetermined or the individual

does notqualifyatthatlevel. Atthetract-level,weconceiveofsocially disadvantagedindividualsasthosewho liveintracts

with either high levels of poverty (as measured by tracts with more than 20% of individuals living below the federal poverty

line) or are “majority-minority,” e.g. are comprised of more than 50% minorities (as measured by individuals who are Black,

American Indian,Asian,NativeHawaiian or Pacific Islander,someother race, or two or moreraces, or Hispanic).

Table 4a: Proposed tract-levelfactors ofsocial disadvantage & statisticsin Tennessee

Count State Percentage

Racial composition(all non-White, owner-occupied households) 234,532 13.6%

Hispanic composition(owner-occupied households) 38,418 2.2%

Poverty status(allpersons) 996,930 15.2%

Source: American Community Survey (ACS), Five-Year Estimates, 2015-2019

Table 4b: Top ten censustracts by percent of minority households(Sampleoftractsocial disadvantage measures)

%of Minority

Households

% of Minority OwnerOccupiedHousing% of Total Population

Below Poverty

Census Tract217.53, Shelby County 91.99 75.79 9.92

Census Tract224.10, Shelby County 96.05 74.13 15.78

Census Tract217.51, Shelby County 89.93 75.04 11.11

Census Tract223.22, Shelby County 96.88 71.27 15.04

Census Tract220.24, Shelby County 93.06 70.61 21.79

Census Tract222.10, Shelby County 98.37 68.27 26.91

Census Tract221.21, Shelby County 93.60 67.11 16.72

Census Tract101.05,DavidsonCounty 75.48 65.81 10.76

Census Tract217.45, Shelby County 89.48 67.26 3.40

Census Tract221.30, Shelby County 97.59 62.64 20.30

Source: American Community Survey (ACS), Five-Year Estimates, 2015-2019
8

Majority-minority (non-whitepersons comprisingmorethan50%ofthepopulation) censustracts areillustrated inFigure3

below.

Figure 3: Percent of Minority (All Non-White) homeowners

Over 15%of Tennesseepopulationwas belowpoverty. Inmorethan two thirds ofmostlysmallrural Tennesseecounties

percentof persons belowpoverty level was abovethestate average, asillustrated in Figure4.

Figure 4: Percent of population below poverty level

County-Level Measures

Finally, if the individual does not qualify based on individual- and tract-level measures, then we recommend using countylevel poverty as the final measure of social disadvantage. Per guidance released by the Treasury, this measure as defined by

counties that have poverty levels greater than 20% over the last three decades, must utilize data from the decennial

Censuses,thelatest of which(2020) has yet to bereleased.
9

General Household, Economic, and Income Characteristics of Tennessee

Households and Homeowners

Homeowners currently paying a mortgage, which is 60% of all homeowners, are generally more advantaged than other

populationsinTennessee. Themedianhomevaluefor this group is approximately $10,000higher than forall homeowners.

Fewer than 25% of homeowners with a mortgage were cost-burdened compared to nearly 50% of renters in the state. A

median homeowner household with a mortgage earns nearly $80,000, compared to $55,000 for all households. Table 4

belowillustratessomegeneral characteristics of Tennesseehomeowners.

Table 4: General Characteristics of TennesseeHouseholds andHomeowners

Total housing units 2,963,486

-Total occupied housing units 2,597,292

-Total owner-occupied housing units 1,722,247

-Total housing units with a mortgage 1,019,481

Households with amortgagepaying 30-35%of income 64,033

Households with amortgage paying over35%of income 183,520

PercentCostburdened with a mortgage(paying30%ormore) 24%

Median valueof owner-occupied housing $167,200

Median valueof owner-occupied witha mortgage $178,500

Median monthly housing costfor households with amortgage $1,244

Median household income(all) $53,320

-Median household income(Owner-occupied with a mortgage) $78,977

Source:AmericanCommunity Survey (ACS), Five-YearEstimates, 2015-2019

Employment in the Most COVID-19 ImpactedSectorsin Tennessee

In March2020,theunemploymentrateinTennesseewas 4%andpeakedto 15.8%in April2020, butthis varied between

counties.vi Since then, unemployment rates have stabilized across the state. The statewide unemployment rate in March

2021 was 5.1%.vii Nonetheless, the impact of the shutdown was felt by those businesses and their employees. Joseph S.

Vavra, using data from BLS, estimated just over 20% of US labor force was employed in the sectors impacted by shut

down.viii Using Vavra’s methodology and the list of four-digit NAICS industry codes,ixwe find that approximately 25% of

Tennessee’s workforcewas employedin sectorsthatarehighly impacted by COVID-19, compared to20%nationwide.x

Figure 7: Employment in the most exposed sectorsin Tennessee

10.2%

1.9% 1.4% 1.3%

5.6% 4.9%

0.0%

2.0%

4.0%

6.0%

8.0%

10.0%

12.0%

Restaurants &

Bars

Travel &

Transportation

Personal

Services

Entertainment Other Sensitive

Retail

Sensitive

Manufacturing

Source: Bureau of Labor Statistics (BLS), Quarterly Census of Employment and Wages, https://data.bls.gov/PDQWeb/en 
10

We use available data to paint a picture of parts of Tennessee that were highly impacted by Covid19 shutdown and

employment loses. Figure 8 below shows the civilian employed population 16 years and over in various major industries.xi

Variousstudieslistmining/oil andgas,transportation, employmentservices,travel arrangements, andleisureand

hospitality as “vulnerable” sectors xii.According to ACS data, as of 2019, a relatively largershare(22.5%) of Tennessee’s

civilian workforcewas employedin“education, healthcareand social assistance” sector,followed by manufacturing with

13%.xiii

22.5%

13.0% 11.7% 14.2%

9.9% 9.8%

6.6% 6.5% 5.8%

Educ., Manufacturing Retail Professional Arts, ent., and Transportation Construction FIRE All Other

health.and soc. services recr., and

Assis. accom. and

food serv.

Source: American Community Survey (ACS), Five-Year Estimates, 2015-2019

Figure 8: Percent of civilian employmentby major industries inTennessee

“Arts, entertainment and recreation and accommodationand foodservices” isidentified as oneofthemostimpacted

sectorsinTennessee. Figure9 belowdisplaysthepercentageemploymentin thisfield across Tennessee’stracts. Sevierand

CockeCounties, for example, are home to several tourist attractions and relatively large percentage of their employed

population is in this sector. In April 2020 both counties experienced unemployment rates well above the state average and

month-over-month increases above20 percentagepoints.

Figure 9: Percent of civilian employment in Arts, Entertainment, Recreation,and Accommodation and Food Services
11

Income and Poverty

Over 15% of Tennessee population were below the federal poverty level, compared to a national level of 13%. In more than

two thirds of mostly small rural Tennessee counties, percent of persons below poverty level was above the state average.

Nearly 40% of Tennessee’s owner households have income less than 100% of AMI. Homeowners with 100 to 140% of AMIxiv

represent18%of Tennesseehomeowners.

Figure 10: Owner households by income percent AMI in Tennessee

Small rural counties such as Union, Fentress, Hancock and Grundy had relatively higher concentration of homeowners with

less than 100%of AMI. In larger, moreurban countiessuch asWilliamson,Montgomery,Washington,Madison,theshareof

homeowners with income less than 100% of AMI was lower than the state average of 40%. The following map shows the

shareof homeowners with incomelessthan100%of AMI.

Figure 11: Percent of homeowners with income less than 100% AMI

6.5% 8.6%

14.9%

10.1%

17.8%

42.0%

0.0%

5.0%

10.0%

15.0%

20.0%

25.0%

30.0%

35.0%

40.0%

45.0%

Less than 30% AMI 30-50% AMI 50-80% AMI 80-100% AMI 100-140% AMI More than 140%

AMI

Source: Comprehensive Housing Affordability Strategy (CHAS), 2013-2017
12

i

The most recent data about Tennessee homeowners indicates that 40% of homeowners are below 100% AMI (Source: 

Comprehensive HousingAffordability Strategy [CHAS], 2013-2017 data).

ii Mortgage Monitor (February 2021). Black Knight. Retrieved from: 

https://cdn.blackknightinc.com/wpcontent/uploads/2021/04/BKI_MM_Feb2021_Report.pdf

iii Tennessee Homeowners During the Pandemic: Mortgage Delinquency, Forbearance, and Foreclosure. (Feb. 1, 2021). THDA Research and

Planning.

Retrieved from https://thda.org/pdf/RP_Delinq_Feb2021.pdf

iv Homeowner Assistance Fund. U.S. Department of the Treasury. Retrieved on May 15, 2021 from 

https://home.treasury.gov/policy-issues/coronavirus/assistance-for-state-local-and-triba l-governments/homeownerassistance-fund

v 13 CFR § 124.103 - Who is socially disadvantaged? Legal Information Institute. Cornell Law School. Retrieved on May 

27, 2021 from: https://www.law.cornell.edu/cfr/text/13/124.103

vi For example, in March 2020, before the shutdown, Rutherford and Williamson Counties had unemployment rates as low as 3.2 percent, 

while Lincoln and Clay Counties had unemployment rate just over 8%. After the shut-down, in April 2020, the unemployment rate reached 

to 30.5% in places like SevierCounty.

vii Sourced from Local Area Unemployment Statistics, Bureau of Labor Statistics (BLS), https://www.bls.gov/lau/data.htm

viii Vavra, J.S., “Shutdown Sectors Represent Large Share of All US Employment.” Chicago, IL: Becker Friedman Institute for Economics at the 

University of Chicago, March 31, 2020. Retrieved from https://bfi.uchicago.edu/insight/finding/shutdown-sectors-represent-large-share-ofall-us-employment/

ix NAICS Classification of sectors impacted by shut down: Restaurants and bars: 7223-7225. Travel and Transportation: 4811,4812, 4853, 4854, 

4859, 4881,4883, 7211. Personal Services: 6212, 8121,8129. Entertainment: 7111, 7112, 7115, 7131, 7132, 7139. Othersensitive retail: 4411,

4412, 4421, 4422,

4481, 4482, 4483,4511,4512, 4522, 4531, 4532, 4539, 5322, 5323, 4243, 4413, 4543. Sensitive Manufacturing: 3352, 3361, 3362, 3363, 3364,

3366, 3371,

3372, 3379, 3399, 4231, 4232, 4239, 3132, 3141, 3149, 3152.

x Sourced from Quarterly Census of Employment and Wages, Bureau of Labor Statistics (BLS), https://data.bls.gov/PDQWeb/en

xi “FIRE” is an acronym for Finance, Insurance, Real Estate and Rental and Leasing. “All Other” includes sectors less than five percent of 

total employmentindividually, which are “Other services, except public administration,” “Public administration,” “Wholesale Trade,” 

“Information,” “Agriculture forestry, fishing and hunting, and mining.”

xii For example, using Mark Zandi’s Research Note, Mark Muro, Robert Maxim, and Jacob Whiton mapped the employment by 

industries. See https://www.brookings.edu/blog/the-avenue/2020/03/17/the-places-a-covid-19-recession-will-likely-hithardest/ for more detailed analysis.

xiii We note that “education, healthcare, and social assistance” were not impacted by the economic shutdowns, but rather, that individuals 

in these sectorsfaced undue burdens and were exposed to increased risk of contracting COVID-19 due to their professions.

xiv Although Treasury’s guidance says that socially disadvantaged populations can have up to 150% of AMI, CHAS does not have income 

breakouts beyond140% of AMI.
13

Homeowner Needs and Minority Disparities in Tennessee

Quantitative data or studies evaluating housing disparities or discrimination in the state of Tennessee are 

predominantly limited to THDA internal research activities and reports. However, a growing body of scholarly and 

industry research examines historic discrimination and contemporary disparities within the U.S. housing market. 

This research informs understanding of potential discriminatory patterns in the state of Tennessee and shows that 

while the most blatant forms of discrimination have declined over time in most communities, racial and ethnic 

discrimination persist in the contemporary U.S. housing market. Research studies present evidence of continued 

residential segregation in U.S. markets due to discriminatory market practices, such as steering potential minority 

homebuyers into lower income neighborhoods or communities of color.

A wide array of studies, including some those cited below, document disparities in the U.S. housing market 

between white households and racial and ethnic minorities, particularly black and Hispanic/Latino households, 

before and after the Great Recession. Black and Hispanic/Latino households have persistently experienced higher 

loan denial rates, higher loan costs and lower home equity compared to white households. Black households face 

the most significant disparities in the U.S. housing finance market when compared with white households, and this 

holds true in the state of Tennessee. Disparities in home equity and value may lead to racial/ethnic disparities in 

household wealth and well-being because the equity built in one’s home is often the greatest source of wealth for 

U.S. households. 

Studies or reports on discrimination and racial/ethnic disparities within the U.S. housing market that contributed 

to the evaluation of which demographic segments have historically experienced discrimination in the housing or 

housing finance market are included below. Citations and summaries of THDA research reports that examine 

housing discrimination and disparities in the state of Tennessee follow.

Citations for Research on Housing Discrimination and Racial/Ethnic Housing Disparities 

Loya, Jose. 2020. Social Stratification in the Mortgage Market Post the Great Recession. Unpublished Doctoral 

Dissertation, University of Pennsylvania.

Taylor, Keeanga-Yamahtta. 2019. Race for Profit: How Banks and the Real Estate Industry Undermined Black 

Homeownership. Chapel Hill: University of North Carolina Press.

Perry, Andre M., Jonathan Rothwell, and David Harshbarger. The Devaluation of Assets in Black Neighborhoods. 

Brookings Institute. February 17, 2021. https://www.brookings.edu/research/devaluation-of-assets-in-blackneighborhoods/

Rothstein, Richard. 2017. The color of law: A forgotten history of how our government segregated America(1st 

ed.). New York, NY: Liveright.

Faber, Jacob W. 2018. Segregation and the Geography of Creditworthiness: Racial Inequality in a Recovered 

Mortgage Market. Housing Policy Debate, 28:2, 215-247.

Faber, Jacob W. and Ingrid Gould Ellen. 2016. Race and the Housing Cycle: Differences in Home Equity Trends 

Among Long-Term Homeowners. Housing Policy Debate 26(3):456–73. 

https://wagner.nyu.edu/files/faculty/publications/Faber_Ellen_2016_Race_and_the_Housing_Cycle.pdf

U.S. Department of Housing and Urban Development, Office of Policy Development and Research (& The Urban 

Institute). June 2013. Housing Discrimination against Racial and Ethnic Minorities, 2012. 

https://www.huduser.gov/portal/Publications/pdf/HUD-514_HDS2012.pdf
14

Citations and Summary of Recent THDA Research and Planning Division Reports –Relevant to Housing 

Discrimination or Racial/Ethnic Housing Disparities

Citation: Tennessee Housing Development Agency (Hulya Arik Ph.D. and Kevin C. McCarthy, AICP). January 2021. 

Issue Brief, Part Two of a Six Part Series Examining Issues of Fair Housing in Tennessee: Racial and Ethnic 

Disparities in Home Mortgage Originations in Tennessee. https://thda.org/pdf/RP_MortgageDisparitiesBrief.pdf

In this research brief, Home Mortgage Disclosure Act (HMDA) data reported by institutions in Tennessee for the 

years 2013-2018, supplemented with information from other sources, is examined to reveal racial disparities and 

identify where possible discriminatory patterns exist in mortgage market outcomes. Relevant findings: 

• While the overall rate of loan denial decreased among all applicants in Tennessee during the period, 

disparities increased. In 2013, loan applications from black loan applicants were 84 percent more likely to be 

denied than white loan applicants. Five years later, black Tennesseans were 90 percent more likely to be 

denied than their white counterparts

• Differences in income across racial groups in Tennessee do not explain racial disparities in loan denial rates. 

Black Tennesseans with the highest incomes are more than twice as likely as their white peers to experience 

a mortgage application denial. Race is a stronger predictor of loan denial than income and associated 

indicators of creditworthiness.

• The gap in homeownership rates between black and white Tennesseans is most pronounced in and around 

Memphis, home to more than 40 percent of black Tennesseans.

Citation: Tennessee Housing Development Agency (Laura Swanson and Teresa Anderson). January 2021. Issue 

Brief, Part One of a Six Part Series Examining Issues of Fair Housing in Tennessee:Fair Housing Perspectives. 

https://thda.org/pdf/RP_Fair-Housing-Perspectives-Final-1-7-2021.pdf

The research brief summarizes key observations from research associated with THDA’s analysis of impediments to 

fair housing choice conducted primarily in 2019. Relevant findings: 

• Black and Hispanic households experience lower income levels than white, non-Hispanic and Asian 

households in Tennessee and higher housing cost burdens. Almost 31 percent of black homeowners and 27 

percent of Hispanic homeowners in Tennessee face cost burdens compared with 18 percent of white 

homeowners (HUD’s Comprehensive Housing Affordable Strategy data).

• Black and Hispanic respondents to a fair housing survey reported being discouraged or denied housing at a 

higher rate than white (non-Hispanic) respondents, whether searching for a home to rent or buy. Thirtyeight percent of black and 50 percent of Hispanic respondents reported being discouraged or denied a 

homeownership opportunity, compared with 26 percent of white (non-Hispanic) respondents. 

• Disability and race are the protected classes associated with the most reports of alleged housing 

discrimination in Tennessee over the past ten years (HUD-FHEO).

Citations:Tennessee Housing Development Agency, Division of Research & Planning (Hulya Arik, Ph.D.). Tennessee 

Home Loan Trends 2018 & 2019: Analysis from Home Mortgage Disclosure Act (HMDA) Data. 

https://thda.org/pdf/RP_HMDA_HomeLoanTrends_2019.pdf; https://thda.org/pdf/RP_HMDA_2018_Report.pdf

THDA regularly publishes home loan trend reports using HMDA data that provide an overview of mortgage market 

activity and lending patterns in Tennessee. Relevant findings related to racial/ethnic disparities from the reports 

(using HMDA data from 2009-2019): 
15

• Since 2013, the share of loans originated for black borrowers has been increasing; however, the share of 

lending for black borrowers was still lower in 2019 than what it was prior to the financial crisis. In 2009, the 

percent of home purchase loans to black borrowers was 7.9 percent and in 2019, it was 7.3 percent. In 

comparison, the percent of home purchase loans to white borrowers was 82.3 percent in 2009 and 80.1 

percent in 2019. The percent of home purchase loans to Hispanic or Latino borrowers in 2019 were the 

highest they have been in the past 10 years at 4.7 percent compared with 2.4 percent in 2009. Tables within 

each report provide detailed data for the last 10 years on loan originations by borrower characteristics. 

• Denial rates for all loan applicants declined year over year in 2018 and 2019. However, denial rates for 

minorities were still higher than for white borrowers with black households facing the highest denial rates. 

• Black borrowers have the lowest average and median income followed byNative Hawaiian borrowers. For 

example, in 2018, 39 percent of black borrowers had “low-to moderate incomes” (at or below 80 percent of 

Area Median Income (AMI)), while 28 percent of all borrowers were LMI.

• Counties that have a high percentage of black households also have a relatively higher percentage of all 

loans originated for black borrowers (compared with other Tennessee counties). However, even among 

counties with a high percent of black households, there is still a large discrepancy between the black 

households share in total households and their share in total home purchase loan originations. 

• Minority borrowers are more likely to use nonconventional loan products. A higher percentage of both black 

and Hispanic/Latino borrowers receive FHA-,VA- or USDA-insured home mortgage loans than white 

borrowers. For example, in 2019, 64 percent of black households and 47 percent of Hispanic households 

purchased a home using a non-conventional loan compared with 34 percent of white households and 17 

percent of Asian households. 

• Since 2011, black borrowers received the highest percentage of higher-priced loans, across all race 

categories. The proportion of black borrowers who received higher-priced home purchase loans was higher 

than white borrowers, even among borrowers within the same income group. 

Community Engagement and Outreach 

Based on the initial Treasury guidance dated April 14, 2021, THDA staff began outreach to the network of housing 

counseling agencies that currently work in the housing education, foreclosure prevention and housing counseling 

arena. Many of these same agencies participated by providing services to homeowners in the Hardest Hit Program. 

Several WebEx meetings were conducted in May 2021 initially to provide the framework of the program provided 

through the guidance. A request was then made of those non-profit agencies to consider the needs of 

homeowners with Covid hardships and present a plan of services by May 31, 2021. In July 2021 THDA held a face 

to face meeting with the Executive Directors of the Tennessee NeighborWorks affiliates to further discuss a broad 

approach to assist HAF applicants.

In May of 2021 THDA staff also conducted a WebEx with the TN Legal Aid group. This consisted of legal aid offices 

throughout the state. A request was made of the TN Legal Aid office to provide a plan of services that could be 

provided to HAF eligible homeowners. TN Legal Aid provided a plan to THDA in early June of 2021. 

On July 28, 2021 THDA held a public board meeting. The HAF program was presented to the board which provided 

time at the board meeting for public comment. Based on the anticipated program activities the board approved 

THDA’s administering the program. In addition, a HAF Public Notice has been published on the THDA.org site and 

will be posted from August 13, 2021 through August 20, 2021. 
16

THDA will use the data analysis provided to target continued outreach to minority communities and households 

with less than 100% AMI. The communication department is working with the executive staff and the research 

staff to identify these priorities. THDA’s communication staff will then develop a marketing plan that should 

include social media advertising, available print ad options, earned media events and purchased advertising. 

Advertising will be appropriately translated for those targeted communities. In addition the contracted call center 

vendor is required to have Spanish speaking call center staff as well as a translation services for other languages. 

THDA also has a contract through the state with a language translation vendor to assist non-English speaking 

homeowners that need assistance as well. In addition our non-profit housing counselor agencies will offer 

assistance to homeowners with limited English proficiency to include but not be limited to application assistance, 

education and counseling. 

Program Design

In an effort to assist homeowners with delinquent and defaulted mortgage loans due to covidrelated hardships; 

the TNHAF Program will offer a reinstatement option, reinstatement plus continued payments and principal 

reduction or extinguishment of amortizing secondary financing (down payment assistance loans provided by nonprofit housing agencies). 

Initial structure of the TNHAF Program will include but not be limited to the following:

• Household income limit of $119,850 statewide

• Must be a 1 to 4 unit single-family residence, located in Tennessee and occupied by homeowner(s) as their 

primary residence.

• Maximum assistance providedis $40,000 per household

• Must have a Covid related hardship after January 21, 2020.

• Funds are provided by a forgivable grant.

The TNHAF program will offer the following assistance to eligible homeowners:

• Mortgage payment assistance which may include but not be limited to; mortgage payments to include 

principal, interest, taxes and insurances, homeowner association fees or liens, lot rentals and/or condo 

association fees. 

• Principal reduction or lien extinguishment of subordinate amortizing liens for borrowers with less than 60% 

AMI provided through non-profit housing agencies. 

• Financial assistance to reinstate a mortgage and/or pay other expenses related to a period of forbearance, 

delinquency, or default associated with the mortgage delinquencies on the homeowner’s primary 

residence.

• Financial assistance to pay delinquent taxes to prevent tax foreclosures. 

• Financial assistance to pay delinquent homeowner association (HOA) dues to prevent HOA foreclosures.
17

• Counseling, advocacy, application assistance, or educational efforts by housing counseling agencies 

approved by HUD, or legal services, targeted to eligible households related to foreclosure prevention or 

displacement. 

THDA works with a strong network of HUD housing counseling agencies in delivering a variety of education and 

counseling services. This network of Housing counseling providers as well as legal aid providers will provide 

services to include but not be limited to application assistance, mortgage crisis education, foreclosure prevention, 

housing counseling and legal advocacy activities.Based on the Treasury guidance 5% of the allocation (up to $8.4 

mil) will be used to pay these service providers. 

Based on the expected activities that a HUD housing counseling agency would provide the anticipated fee schedule 

for services follows: 

First Tier- Application assistance-specific to HAF applicants that may struggle to complete the application, 

understanddocumentation requirements or have limited access to the internet or computers. -Fee earned $700 

per eligible applicant. This will not be earned on those applicants that have the ability and desire to do this on their 

own. 

Second Tier- Education piece to include; understanding forbearance, loss mitigation options, understanding FHA 

claim, understanding the foreclosure moratorium and how it applies, available options under private mortgage 

insurers, and working best with your servicer in a crisis. THDA’s internal HUD counselors have been developing the 

curriculum. –Fee earned $500

Third Tier- Counseling –one on one crisis counseling and budgeting. This will be required for homeowners that 

receive continued payments after reinstatement of their loan. These homeowners have recaptured less than 90% 

of their pre-pandemic income. Fee earned $700

At the end of foreclosure moratoriums the anticipation is that there will be a glut of foreclosure filings. Grant 

funding will be provided to allow HUD Counseling Agencies and TN Legal Aid to build capacity, increase staffing, or

provide one on one advocate services or legal services for borrowers finding themselves trying to maneuver 

through foreclosure action. 

The TNHAF program will begin with a pilot that will provide assistance to the THDA MRB portfolio. THDA MRB 

portfolio loans are 97% government loans with the large majority of homeowners at our below 100% AMI. Both 

the Pilot and Phase 1 will provide reinstatement and reinstatement to include future payments. It is anticipated 

that the TNHAF Pilot will begin in mid- August and Phase 1, which will open the program up to other homeowners 

with outside servicers, in October. Phase 2 will provide principal reduction on secondary amortizing loans that 

were provided to the homeowner through a non-profit housing agency. The homeowners receiving Phase 2 funds 

will be at or below 60% of the national AMI. The Phase 2 eligible homeowners are the most fragile population with 

limited discretionary income and most like to have been effected by income losses due to the covid pandemic. 

THDA expects Phase 2 to begin early February. 
18

The following TNHAF Term Sheets (3) cover the Pilot, Phase 1 and Phase 2:

Tennessee Housing Development Agency

Homeowners Assistance Fund Program 

(HAF)

Summary Guideline

Pilot

1. Program overview The Tennessee Housing Development Agency (THDA) Tennessee 

Homeowner Assistance Fund (TNHAF) will provide assistance to 

homeowners for the purpose of preventing homeowner mortgage 

delinquencies, defaults, foreclosures, and displacements of homeowners 

experiencing financial hardship after January 21, 2020. 

HAF funds will be used to eliminate or reduce past due payments and other 

delinquent amounts, including payments under a forbearance plan.

HAF funds may be used to bring account fully current, with no remaining 

delinquent amounts, and to repay amounts advanced by the lender or 

servicer on the borrower’s behalf for property charges, including property 

taxes, hazard insurance premiums, flood or wind insurance premiums, 

ground rents, condominium fees, cooperative maintenance fees, planned 

unit development fees, homeowners’ association fees or utilities that the 

servicer advanced to protect lien position. Payment may also include any 

reasonably required legal fees.

HAF funds may be used to provide payment assistance to homeowners 

unable to make full mortgage payments due to a continuing financial 

hardship associated with the Coronavirus pandemic. 

HAF funds may be used to supplement other loss mitigation options offered 

by the servicer under investor requirements or where, without HAF funds, 

the homeowner would not qualify for that loss mitigation option.

2. Maximum amount of 

assistance per homeowner

Each Homeowner will be eligible for up to $40,000 through this program to be 

used only for the homeowner’s primary residence.
19

3. Target Population /Areas This program will be available in all Tennessee counties. Not less than 

60% of available TNHAF funds must be used for homeowners having 

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

to 100% of the median income of the United States, whichever is greater. 

Any amount not made available to homeowners that meet this incometargeting requirement must be prioritized for assistance to socially 

disadvantaged individuals, with funds remaining after such prioritization 

being made available for other eligible homeowners.

4. Program Funds • Pilot Allocation $16,823,903

• Program Funds $8,411,952

• Administrative Funds of $8,411,952 included in the administrative 

allocation total of $25,235,405.

5. Homeowner eligibility Criteria 

and documentation criteria

In order to be eligible for assistance under TNHAF Pilot Program, homeowners 

must meet the following criteria:

• Have a mortgage loan serviced by Volunteer Mortgage Loan Services.

• Homeowner has experienced an eligible financial hardship (lasting at 

least 30 days), related to the Coronavirus Pandemic, of involuntary 

loss of income equal to or greater than 10% due to a death of a 

spouse/domestic partner or occupying co-borrower, temporary loss 

of wages or an eligible increase in expenses related to the Coronavirus 

Pandemic (as defined in the program guidelines) which occurred after 

the purchase of the home and occurred or was ongoing after January 

21, 2020.

• Homeowner is required to complete and sign a financial hardship 

affidavit with appropriate documentation as to the cause of the 

hardship, as specified in the program guidelines.

• Homeowner is required to sign program specific documents as listed 

in the program guide. 

• Homeowner is required to complete housing education/ counseling 

before funds are released. Type of counseling required will be 

determined by the type of assistance provided.

Eligibility for program assistance will be determined by THDA in its sole 

discretion, based on the criteria stated above and as otherwise set forth in the 

program guidelines. The TNHAF funds will be allocated as dictated by Treasury 

requirements.
20

6. Mortgage Eligibility Criteria Eligible mortgage means any credit transaction (1) that is secured by a 

mortgage, deed of trust, or other consensual security interest on a principal 

residence of a borrower that is (a) a one to four unit dwelling, or (b) a 

residential real property that includes a one to four unit dwelling; and (2) the 

unpaid principal balance(s) of which was at the time of origination, not more 

than the conforming loan limit. 

Tennessee owner-occupied, primary residences only.

7. Program Exclusions • Homeowner is in "Active" Bankruptcy, unless permission to proceed 

is obtained from the Bankruptcy Court and it must be submitted with 

the initial application. 

• Non-arm’s Length Land contracts

• Ownership Structures other than a “Natural Person” (i.e., LLP, LP or 

LLC.)

****See HAF Program Guide for additional exclusions.

8. Duration of Assistance Funds will not be provided past December 1, 2026.

9. Estimated Number of 

Participating Households

Approximately 550 Households

10. Program Inception/Duration Pilot program will launch August 16, 2021 or sooner.

HAF Pilot applications will end when Pilot funds are fully reserved or by 

September 30, 2026, whichever comes first.

Funding completed by December 1, 2026.

11. Program Interactions with 

Other HFA Programs

No Restrictions.

12. Program Leverage with Other 

Financial Resources

No Restrictions.
21

Tennessee Housing Development Agency

Homeowners Assistance Fund Program 

(HAF)

Summary Guideline

Phase 1

1. Program Overview The Tennessee Housing Development Agency (THDA) Tennessee 

Homeowner Assistance Fund (TNHAF) will provide assistance to 

homeowners for the purpose of preventing homeowner mortgage 

delinquencies, defaults, foreclosures, and displacements of 

homeowners experiencing financial hardship after January 21, 2020. 

HAF funds will be used to eliminate or reduce past due payments and other 

delinquent amounts, including payments under a forbearance plan.

HAF funds may be used to bring account fully current, with no remaining 

delinquent amounts, and to repay amounts advanced by the lender or 

servicer on the borrower’s behalf for property charges, including property 

taxes, hazard insurance premiums, flood or wind insurance premiums, 

ground rents, condominium fees, cooperative maintenance fees, planned 

unit development fees, homeowners’ association fees or utilities that the 

servicer advanced to protect lien position. Payment may also include any 

reasonably required legal fees.

HAF funds may be used to provide payment assistance to homeowners 

unable to make full mortgage payments due to a continuing financial 

hardship associated with the Coronavirus pandemic. 

HAF funds may be used to supplement other loss mitigation options offered 

by the servicer under investor requirements or where, without HAF funds, 

the homeowner would not qualify for that loss mitigation option.

2. Maximum Amount of Assistance 

Per Homeowner

Each Homeowner will be eligible for up to $40,000 through this program to be 

used only for the homeowner’s primary residence.
22

3. Target Population /Areas This program will be available in all Tennessee counties. Not less than 

60% of available TNHAF funds must be used for homeowners having 

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

to 100% of the median income of the United States, whichever is 

greater. Any amount not made available to homeowners that meet 

this income-targeting requirement must be prioritized for assistance to 

socially disadvantaged individuals, with funds remaining after such 

prioritization being made available for other eligible homeowners.

4. Program Funds • Total Allocation $168,239,035

• Program Funds for Phase 1 $106,179,276

• Reserved for counseling fees/legal aid assistance $8,411,952

• Administrative Funds $25,235,855 (Total for all program phases)

5. Homeowner Eligibility Criteria and 

Documentation Criteria

In order to be eligible for assistance under the TNHAF Program, 

homeowners must meet the following criteria:

• Homeowner has experienced an eligible financial hardship (lasting at 

least 30 days), related to the Coronavirus Pandemic, of involuntary 

loss of income equal to or greater than 10% due to a death of a 

spouse/domestic partner or occupying co-borrower, temporary loss 

of wages or an eligible increase in expenses related to the 

Coronavirus Pandemic (as defined in the program guidelines) which 

occurred after the purchase of the home and occurred or was 

ongoing after January 21, 2020.

• Homeowner is required to complete and sign a financial hardship 

affidavit with appropriate documentation as to the cause of the 

hardship, as specified in the program guidelines.

• Homeowner is required to sign program specific documents as listed 

in the program guide. 

• Homeowner is required to complete housing education/ counseling 

before funds are released. Type of counseling required will be 

determined by the type of assistance provided.

Eligibility for program assistance will be determined by THDA in its sole 

discretion, based on the criteria stated above and as otherwise set forth in 

the program guidelines. The TNHAF funds will be allocated as dictated by 

Treasury requirements.
23

6. Mortgage Eligibility Criteria Eligible mortgage means any credit transaction (1) that is secured by a 

mortgage, deed of trust, or other consensual security interest on a principal 

residence of a borrower that is (a) a one to four unit dwelling, or (b) a 

residential real property that includes a one to four unit dwelling; and (2) the 

unpaid principal balance(s) of which was at the time of origination, not more 

than the conforming loan limit. 

Tennessee owner-occupied, primary residences only.

7. Program Exclusions • Homeowner is in "Active" Bankruptcy, unless permission to proceed 

is obtained from the Bankruptcy Court and it must be submitted 

with the initial application. 

• Non-arm’s Length Land contracts

• Ownership Structures other than a “Natural Person” (i.e., LLP, LP or 

LLC.)

 See HAF Program Guide for additional exclusions.

8. Duration of Assistance Funds will not be provided past December 1, 2026.

9. Estimated Number of Participating 

Households

Approximately 3,800 Households

10. Program Inception/ Duration HAF applications will end September 30, 2026 or until funds are fully 

reserved, whichever comes first.

Funding completed by December 1, 2026. 

11. Program Interactions with Other 

HFA Programs

No Restrictions.

12. Program Leverage with Other 

Financial Resources

No Restrictions.
24

Tennessee Housing Development Agency

Homeowners Assistance Fund Program 

(HAF)

Summary Guideline

Phase 2

1. Program overview The Tennessee Housing Development Agency (THDA) Tennessee 

Homeowner Assistance Fund (TNHAF) will provide assistance to 

homeowners for the purpose of preventing homeowner mortgage 

delinquencies, defaults, foreclosures, and displacements of 

homeowners experiencing financial hardship after January 21, 2020. 

HAF funds will be used to provide a principal reduction of amortizing 

secondary liens which were originated by an eligible non-profit agency as 

down payment assistance. The homeowner must meet the program

eligibility criteria for a qualifying hardship and fall below 60% of the national 

AMI.

Homeowners who have already received assistance for reinstatement of 

first mortgage liens and other qualifying assistance may receive principal 

reduction of up to any remaining funds up to the program limit of $40,000.

2. Maximum amount of 

assistance per homeowner

Each Homeowner will be eligible for up to $40,000 through this program to be 

used only for the homeowner’s primary residence.

3. Target Population /Areas Homeowners with incomes at or below 60% national AMI, who have an 

amortizing second lien used as down payment assistance.

4. Program Funds • Total Allocation $168,239,035
25

• Program Funds $20,000,000

• Total Administrative Funds $25,235,855 (Total for all program 

phases)

5. Homeowner eligibility Criteria 

and documentation criteria

In order to be eligible for assistance under TNHAF Principal Reduction, 

homeowners must meet the following criteria:

• Have an amortizing second mortgage lien originated through an 

eligible non-profit agency as down payment assistance.

• Homeowner’s income is at or below 60% AMI.

• Homeowner has experienced an eligible financial hardship (lasting at 

least 30 days), related to the Coronavirus Pandemic, of involuntary

loss of income equal to or greater than 10% due to a death of a 

spouse/domestic partner or occupying co-borrower, temporary loss 

of wages or an eligible increase in expenses related to the 

Coronavirus Pandemic (as defined in the program guidelines) which 

occurred after the purchase of the home and occurred or was 

ongoing after January 21, 2020.

• Homeowner is required to complete and sign a financial hardship 

affidavit with appropriate documentation as to the cause of the 

hardship, as specified in the program guidelines.

• Homeowner is required to sign program specific documents as listed 

in the program guide. 

• Homeowner is required to complete housing education/ counseling 

before funds are released. Type of counseling required will be 

determined by the type of assistance provided.

Eligibility for program assistance will be determined by THDA in its sole 

discretion, based on the criteria stated above and as otherwise set forth in 

the program guidelines. The TNHAF funds will be allocated as dictated by 

Treasury requirements.

6. Mortgage Eligibility Criteria • Must be an amortizing second mortgage lien originated through an 

eligible non-profit agency as down payment assistance.

• Tennessee owner-occupied, primary residences only.

7. Program Exclusions • Homeowner is in "Active" Bankruptcy, unless permission to proceed 

is obtained from the Bankruptcy Court and it must be submitted with 

the initial application. 

• Non-arm’s Length Land contracts

• Ownership Structures other than a “Natural Person” (i.e., LLP, LP or 

LLC.)

** **See HAF Program Guide for additional exclusions.
26

8. Duration of Assistance Funds will not be provided past December 1, 2026.

9. Estimated Number of 

Participating Households

Approximately 500 Households

10. Program Inception/ Duration Phase 2 will launch on February 1, 2022.

HAF applications will end September 30, 2026 or until funds are fully 

reserved, whichever comes first.

Funding completed by December 1, 2026. 

11. Program Interactions with Other 

HFA Programs

No Restrictions.

12. Program Leverage with Other 

Financial Resources

No Restrictions.
27

TNHAF Budget

Tennessee was allocated $168,239,035 in HAF funding. THDA will dedicate 15% of the funds to the administrative 

budget ($25,235,855), 5% to HUD Counseling Agency service fees, capacity funds and Legal Aid services 

($8,411,951) and the remainder to program benefits to homeowners ($134,591,229). Attached is a sample budget 

items that are to be expected for the administration of the program. 

For HAF Schedule

Cumulative Actual 

Expenses Actual Budget % Used Prposed NEW Budget % Reduction in Budget

Line One-time / Start-Up Expenses:

Line 42 Initial Personnel #DIV/0! #DIV/0! $0.00

Line 43 Building, Equipment, Technology #DIV/0! #DIV/0! $0.00

Line 44 Professional Services #DIV/0! #DIV/0! $0.00

Line 45 Supplies / Miscellaneous #DIV/0! #DIV/0! $0.00

Line 46 Marketing /Communications #DIV/0! #DIV/0! $0.00

Line 47 Travel #DIV/0! #DIV/0! $0.00

Line 48 Website development /Translation #DIV/0! #DIV/0! $0.00

Line 49 Contingency 0% $0.00

Line 50 Subtotal $0.00

Operating / Administrative Expenses:

Line 51 Salaries #DIV/0! #DIV/0! $0.00

Line 52 Professional Services (Legal, Compliance, Audit, Monitoring) #DIV/0! #DIV/0! $0.00

Line 53 Underwriting and Processing Services #DIV/0! #DIV/0! $0.00

Line 54 Call Center Services 0% $0.00

Line 55 Information Technology & Communications #DIV/0! #DIV/0! $0.00

Line 56 Office Supplies/Postage and Delivery/Subscriptions #DIV/0! #DIV/0! $0.00

Line 57 Risk Management/ Insurance 0% $0.00

Line 58 Training #DIV/0! #DIV/0! $0.00

Line 59 Marketing/PR #DIV/0! #DIV/0! $0.00

Line 60 Miscellaneous #DIV/0! 0% $0.00

Line 61 Subtotal $0.00 $0.00 $0.00 #DIV/0! $0.00

Transaction Related Expenses:

Line 62 #DIV/0! #DIV/0! $0.00

Line 63 Wire Transfer Fees #DIV/0! #DIV/0! $0.00

Hud Agency/Legal Aid Capacity Funding $0.00

Line 65 Application Assistance #DIV/0! $0.00

Line 66 HAF Education $0.00

Line 67 HAF Counseling #DIV/0! #DIV/0! $0.00

Line 68 Legal services/ legal aid $0.00 #DIV/0! $0.00

Line 69 Subtotal $0.00 $0.00 $0.00 $0.00

Grand Total $0.00 $0.00 $0.00 $0.00 ##### $0.00

Counseling / legal aid services (5% of allocation)

% of Total Award 20.00% 0%

Award Amount

RED % = Red % indicates reduction in line item budget

Amount of reduction in 

Admin Budget
28

Program Goals

• Targeting vulnerable populations-minority households, households at or below 100% AMI, Households 

living in counties where poverty level is above 20% and other populations that are identified as socially 

disadvantaged. 

Measurements-number of applicants served and percentage of applicants served in targeted 

populations. Number of outreach events in targeted communities. Number of advertising and 

media opportunities serving targeted populations. 

• Reducing mortgage delinquency, reinstating mortgage loans, avoiding foreclosures-Number of

households with reinstated mortgages/ number of applicants. 

Measurement-Number or percentage of households that remain current for the next consecutive 

12 month after reinstatement. Percentage of targeted population households reinstated > 60%

• Principal reductions of amortizing secondary financing mortgages for households below 60% AMIreducing mortgage/housing debt burden of households with limited income. 

Measurements-Number of amortizing secondary liens reduced or released that were originated /

funded by non-profit housing agencies. Household housing debt ratios reduced by 10% or more. 
29

Readiness

The Tennessee Housing Development Agency (THDA) is a State agency that was established by the Tennessee 

General Assembly in 1973 (TCA 13-23-120). THDA is committed to the belief that housing is a basic human need that 

has profound impacts, both social and economic, on individuals and communities. Safe, sound, affordable housing 

is essential to a healthy household, educational achievement, successful employment, and the stability and safety 

of the neighborhood. THDA has a broad portfolio of housing assistance programs and continues to vigorously 

develop a network of industry and municipal partners for their delivery.

In an effort to collaborate on a uniform program, per Treasury’s guidance, THDA is working through its network of 

HFAs in the southeast region to work on common goals to administer theprogram. In addition staff has 

participated in working groups with NCSHA staff and leaders of the larger national servicers over the past several 

months to enhance the CDF to include needed data fields pertaining to the HAF program. As a prior HHF state,

staff has also contributed to conversations with non- HHF states to share best practices, challenges and prior HHF 

documents for review.

THDA also intends to work with our network of HUD approved housing counselors to provide borrower application 

assistance, education and financial crisis counseling. THDA has more than 25 years invested in its deep working 

relationship with its network of non-profit housing agencies (HUD). THDA utilized their services during the HHF 

program which severed over 7500 in its unemployment program, Keep My TN Home and it is because of this 

relationship that THDA immediately engaged this group to discuss the challenges observed in the current 

pandemic crisis. Their business activities reachthose populations that need the assistance but are least likely to 

apply. This includes, but is not limited to, Latinos, immigrants, minorities, urban homeowners, seniors,rural 

residents, and lower-income households which are the HAF targeted populations. These populations are more 

comfortable working with counselors/providers that are imbedded in their communities. Their mission aligns well 

with THDA’s and they work in a holistic approach, knowing that funding alone will notsolve the issue but 

education and housing counseling are required to create the successfulstabilization of homeownership going 

forward. 

THDA staff is well prepared and experienced in creating programs based on instructions from funders and adhering 

to compliance requirements while also maintain accuracy in reporting. Not only did THDA successfully administer 

the HHF funds in Tennessee but THDA continues to administer other federal, statewide or local programs that 

assist Tennesseans recover, rebuild or shore up non-profit activities.

THDA has contracted with vendors and worked for the past several months to secure a software provider, a call 

center team and processing/underwriting providers for the HAF program. Staff have completed a program guide 

which has been provided to the processing and underwriting vendor. THDA has also hired internal staff as well as 

converting several staff that had worked on the HHF program for its last 5 years. Policies and procedures are being 

created by staff. These procedures will include compliance process in order to review vendor work, homeowner 

eligibility and payment processing.

THDA is fortunate to have had the experience of administering the Hardest Hit Funds as a response to the 

mortgage crisis a decade ago. The Hardest Hit Fund was also provided through the U.S. Department of Treasury. 

THDA staff will take the lessons learned from the administration of the Hardest Hit Funds as it works through the 

process of developing a program, creating the internal processes, while building a strong network of external 

partners and vendors to assist with the program roll out.