ALABAMA HOMEOWNER ASSISTANCE FUND PLAN 1

 

DRAFT

AUGUST 2021
ALABAMA HOMEOWNER ASSISTANCE FUND PLAN 2

TABLE OF CONTENTS

Introduction .................................................................................................................................................3

Homeowner Needs and Engagement .....................................................................................................4

2.1 DATA-DRIVEN NEEDS ASSESSMENT .......................................................................................4

2.2 PUBLIC PARTICIPATION AND COMMUNITY ENGAGEMENT...............................................16

Program Design........................................................................................................................................18

3.1 PROGRAM STRUCTURE..............................................................................................................18

3.2 CONTINUED ASSESSMENT OF HOMEOWNER NEEDS........................................................20

3.3 ELIGIBILITY REQUIREMENTS.....................................................................................................21

3.4 TARGETING AND PRIORITIZATION...........................................................................................22

3.5 APPLICATION PROCESS.............................................................................................................22

3.6 PAYMENT PROCESS....................................................................................................................22

3.7 MARKETING AND OUTREACH EFFORTS.................................................................................23

3.8 BEST PRACTICES AND COORDINATION WITH HAF PARTICIPANTS................................23

Performance Goals .................................................................................................................................24

Readiness .................................................................................................................................................25

5.1 STAFFING AND SYSTEMS..........................................................................................................25

5.2 PROGRAM ADMINISTRATION....................................................................................................25

5.3 CALL CENTER................................................................................................................................26

5.4 APPLICATION PROCESSING......................................................................................................26

5.5 SYSTEM SOLUTION.....................................................................................................................27

5.6 PILOT PROGRAM..........................................................................................................................27

Administrative & Program Budget .........................................................................................................28
ALABAMA HOMEOWNER ASSISTANCE FUND PLAN 3

Introduction

The Alabama Housing Finance Authority (“AHFA”) will be administering the Homeowner 

Assistance Fund (“HAF”) program for the state of Alabama. The HAF program was established to 

mitigate financial hardship associated with the coronavirus pandemic by providing funds to eligible 

entities for the purpose of preventing homeowner mortgage delinquencies, defaults, foreclosures, 

loss of utilities or home energy services, and displacements of homeowners experiencing financial 

hardship after January 21, 2020 (“Financial Hardship”). 

The American Rescue Plan Act (“ARPA”) was signed into law on March 11, 2021, setting aside a 

total of $1.9 trillion in federal funding for coronavirus pandemic related expenses and needs. 

Approximately $9.9 billion in federal funding was set aside for states, territories, and tribal 

governments to administer HAF programs assisting low-to-moderate income homeowners. AHFA 

has developed this proposed plan (the “Plan”) for evaluation by U.S. Treasury (“Treasury”) 

outlining the program design and strategy for distribution of Alabama’s $125.6 million allocation.1

States were required to submit a Notice of Funds Request by April 25, 2021 and enter into a 

Financial Assistance Agreement with Treasury to receive funding. In addition, states were given 

the option to opt-in and receive 10 percent of their allocation up front to fund and administer a 

pilot program. The state of Alabama submitted its notice and agreement for their total allocation 

of $125,695,705. By Act No. 2021-443, the Alabama Legislature appropriated the HAF funds to 

the Alabama Department of Finance to be subdelegated to AHFA to administer the state program. 

Additionally, AHFA opted-in for the 10 percent up-front allocation and has chosen to administer a 

pilot program which will be summarized within the Plan. States are required to submit their 

implementation plan or a letter outlining when the implementation plan will be submitted. AHFA 

submitted a letter to Treasury on June 24, 2021 acknowledging its intent to submit the Plan no 

later than September 30, 2021, pending additional guidance, FAQs, and/or commentary by 

Treasury regarding the specific regulatory requirements for HAF spending and programing. 

AHFA and the state of Alabama stand ready to launch the HAF program upon Treasury’s approval 

and look forward to assisting the state’s most vulnerable homeowners. AHFA is available to 

provide additional details or answer questions as needed by Treasury. 

1 U.S. Department of the Treasury, “Data and Methodology for State and Territory Allocations,” April 2021, 

https://home.treasury.gov/system/files/136/HAF-state-territory-data-and-allocations.pdf

1
ALABAMA HOMEOWNER ASSISTANCE FUND PLAN 4

Homeowner Needs

and Engagement

2.1 DATA-DRIVEN NEEDS ASSESSMENT

AHFA has conducted a data-driven needs assessment to estimate the impact of the COVID-19 

pandemic on homeowners across the state. AHFA obtained data from the U.S. Census Bureau, 

AHFA’s own servicing portfolio of US Department of Agriculture (“USDA”), Federal Housing 

Administration (“FHA”), and Department of Veteran Affairs (“VA”) loans, CoreLogic MarketTrends 

reports for loan performance, and Centers for Disease Control and Prevention indexes to assess 

the impact on employment rates and income loss for homeowners in the state. As of June 30, 

2021, the state of Alabama reported 551,918 COVID cases which has added additional burdens 

to homeowners in Alabama for those who have not been able to work, experienced death in the 

family, or assisted with loved ones who contracted COVID-19.2 According to the U.S. Bureau of 

Labor Statistics, the state’s unemployment rate peaked at 13 percent.3 Loss of employment 

income was reported for 45 percent of households with 37 percent of the total comprised of 

individuals within Socially Disadvantaged groups.4

A socially disadvantaged individual, as defined per U.S. Treasury guidance, are those whose 

ability to purchase or own a home has been impaired due to diminished access to credit on 

reasonable terms as compared to others in comparable economic circumstances, based on 

disparities in homeownership rates in the HAF participant’s jurisdiction as documented by the U.S. 

Census. The impairment must stem from circumstances beyond their control. Indicators of 

impairment under this definition may include being a (1) member of a group that has been 

subjected to racial or ethnic prejudice or cultural bias within American society; (2) resident of a 

majority-minority Census tract; (3) individual with limited English proficiency; (4) resident of a U.S. 

territory, Indian reservation, or Hawaiian Home Land, or (5) individual who lives in a persistentpoverty county, meaning any county that has had 20% or more of its population living in poverty 

over the past 30 years as measured by the three most recent decennial censuses. 

2 Centers for Disease Control and Prevention “United States COVID-19 Cases and Deaths by State over 

Time,” July 2021, https://data.cdc.gov/Case-Surveillance/United-States-COVID-19-Cases-and-Deaths-byState-o/9mfq-cb36/data 3 U.S. Bureau of Labor Statistics “Local Area Unemployment Statistics,” June 2021, 

https://www.bls.gov/lau/#tables 

4 U.S. Census Bureau Household Pulse Survey (Week 6)

2
ALABAMA HOMEOWNER ASSISTANCE FUND PLAN 5

Housing Discrimination 

According to a 2021 survey by the National Association of Realtors the following homebuyers

across the nation have experienced discrimination in real estate transactions:5

• Hispanic home buyers (one percent)

• Asian/Pacific Islander home buyers (five percent)

• Black/African American (seven percent)

Additionally, the 2021 Snapshot of Race 

and Home Buying in America, Native 

Americans and all other minorities 

represent only 2% of homebuyers 

collectively. AHFA recognizes this disparity 

in homeownership rates and acknowledges 

that these individuals fall within the 

definition of socially disadvantaged and will 

ensure these homeowners are included in 

targeted outreach efforts.

AHFA recognizes that these individuals fall 

within the definition of socially 

disadvantaged and will ensure these 

homeowners are included in targeted 

outreach efforts.

Majority-Minority Census Tracts

In addition to total owner-occupied 

households, AHFA assessed needs across 

the state by majority-minority census tracts 

which make up part of the socially 

disadvantaged population. AHFA obtained 

data from ACS and compared AMI limit 

rates per county to determine homeowners 

that reside in majority-minority census 

tracts to be 170,619.6 Exhibit 1 depicts the 

census tracts that are majority-minority 

populated throughout the state. 

5 National Association of Realtors Research Group “2021 Snapshot of Race and Home Buying in 

America,” February 2021

6 U.S. Census Bureau's American Community Survey (ACS) 2015-2019 5-year estimates, Table(s) 

B03002

EXHIBIT 1

OWNER-OCCUPIED HOUSEHOLDS 

- 150% AMI OR LESS

MAJORITY-MINORITY US CENSUS 
ALABAMA HOMEOWNER ASSISTANCE FUND PLAN 6

Limited English Proficiency Households 

AHFA inspected data sources from Data USA to identify certain populations with limited English 

proficiency, noting 3.59% of the population speaks Spanish only, and less than one percent of the 

population speaks Chinese only, and Korean only. As of 2019, the most prevalent non-English 

language spoken in the state is Spanish. AHFA understands that individuals in this group are 

included within the socially disadvantaged group. Exhibit 2 illustrates the composition of nonEnglish speakers within the state where Spanish accounts for 65% of all non-English speakers.7

AHFA will use this information to inform its public communications, targeted marketing and 

outreach and program materials. 

EXHIBIT 2 COMPOSITION OF NON-NATIVE ENGLISH SPEAKERS

Indian Tribes and Reservations 

The state of Alabama recognizes the nine tribes within the state: (1) Cher-O-Creek Intra Tribal 

Indians, (2) Cherokee Tribe of Northeast Alabama, (3) Echota Cherokee Tribe of Alabama, (4) MaChis Lower Indian Tribe of Alabama, (5) MOWA Band of Choctaw Indians, (6) Piqua Shawnee 

Tribe, (7) Poarch Band of Creek Indians, (8) Southeastern Mvskoke Nation, and (9) United 

Cherokee Ani-Yun-Wiya Nation. Any enrolled citizen of these tribes within the state shall be 

recognized as Native American. AHFA recognizes these individuals meet the definition of socially 

disadvantaged and will included in targeted outreach efforts.

7 Data USA “Non-English Speakers,” August 2021, https://datausa.io/profile/geo/alabama#demographics
ALABAMA HOMEOWNER ASSISTANCE FUND PLAN 7

AHFA notes that two Indian reservations are in Alabama: (1) Poarch Band of Creek Indians and 

(2) MOWA Band of Choctaw Indians and have a total of five owner-occupied households8 and

eight owner-occupied households,

9 respectively. 

Persistent Poverty Counties 

Further makeup of the socially disadvantaged population includes homeowners that reside in a 

persistent poverty county. AHFA obtained data from the Congressional Research Service and 

identified the following counties as persistent poverty counties: Barbour, Bibb, Bullock, Butler, 

Choctaw, Conecuh, Dallas, Escambia, Greene, Hale, Lowndes, Macon, Marengo, Monroe, Perry, 

Pickens, Pike, Sumter, and Wilcox.10 AHFA assessed the owner-occupied households that are 

150% AMI or less that are included with these counties as shown within Exhibit 3.11

EXHIBIT 3 PERSISTENT POVERTY COUNTIES

8 My Tribal Area “Poarch Creek Reservation and Off-Reservation Trust Land, AL-FL,” August 2021, 

https://www.census.gov/tribal/?st=01&aianihh=2865

9 My Tribal Area “MOWA Choctaw Reservation (state), AL,” August 2021, 

https://www.census.gov/tribal/?st=01&aianihh=9240

10 Congressional Research Service “The 10-20-30 Provision: Defining Persistent Poverty Counties” 

February 24, 2021

11 U.S. Census Bureau's American Community Survey (ACS) 2015-2019 5-year estimates, Table(s) 

B25003, B25003B, B25003C, B25003D, B25003E, B25003F, B25003G, B25003H, B25003I, December 

2020
ALABAMA HOMEOWNER ASSISTANCE FUND PLAN 8

Homeowners who experienced hardships and job loss during this period increased the need for 

assistance. Pursuant to Treasury guidelines, homeowners with total household income less than 

150% AMI, as determined by HUD, is one of the eligibility requirements under the Homeowner 

Assistance Fund. AHFA incorporated this income limit into the data analysis of the needs 

assessment when determining target populations and potentially eligible homeowners across the 

state. AHFA obtained data from the American Community Survey (“ACS”) and identified 

1,284,748 owner-occupied households within the state.12 Of these homeowners, AHFA assessed 

the income levels per homeowner and by county to determine that 860,233 of the homeowners 

are 150% AMI or less. Further analysis shows us that of these homeowners that are 150% AMI or 

less, 162,486 hold mortgages that are in good standing and 26,441 hold troubled loans as detailed 

in the following Sections. Exhibit 4 below identifies the owner-occupied households that are 150% 

AMI or less by county for the state. 

EXHIBIT 4 OWNER-OCCUPIED HOUSEHOLDS - 150% AMI OR LESS

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

12 U.S. Census Bureau's American Community Survey (ACS) 2015-2019 5-year estimates, Table(s) 

B25003, B25003B, B25003C, B25003D, B25003E, B25003F, B25003G, B25003H, B25003I, December 

2020
ALABAMA HOMEOWNER ASSISTANCE FUND PLAN 9

Loan Performance Data 

AHFA recognizes that homeowners may not have experienced delinquencies but have maintained 

good standing on their mortgages by other means. AHFA obtained ACS data and assessed for 

borrowers that are 150% AMI and less and noted 162,486 homeowners that have loans in good 

standing. These homeowners are determined to meet the income requirement and will be 

assessed for eligibility for prospective mortgage payments. 

AHFA assessed homeowner needs across the state and identified 26,441 troubled loans that 

range from 30 days past due to foreclosure.13 AHFA obtained FHA data for Real Estate Owned 

(“REO”) properties and determined that 719 properties were foreclosed from January 2020 to 

May 2021 indicating a portion of the state’s post-foreclosure homes.14 Exhibit 5 below indicates 

the breakout of delinquencies by category.

EXHIBIT 5

Total State Need 

30 and 60 days past due 2,885

90+ days past due 22,744

Foreclosures 812

Total Need 26,441 

To further assist homeowners, AHFA assessed the potential for lien extinguishment. Based on an 

extrapolation of Alabama loans serviced by AHFA, compared to CoreLogic Market Trends data15, 

AHFA identified an estimate of 2,661 (or approximately 10 percent of total need) loans in need of 

lien extinguishment. 16

13 U.S. Census Bureau American Community Survey (ACS) 2015-2019 5-year estimates, Tables B25009, 

B25010, B19019, Special Reference 102100 (3857), December 2020 14 U.S. Department of Housing and Urban Development’s Real Estate Owned (REO) “FHA Single Family 

REO Properties for Sale,” July 2021. Foreclosure data includes all foreclosures and post-foreclosures until 

termination. The state was not able to obtain current data on USDA, VA, and other loan types for postforeclosure evictions. 

15 CoreLogic Market Trends Report, “Market Trends Data by State,” January 2021 16 Atlanta Fed calculations using Black Knight’s McDash Flash daily mortgage performance data (available 

with a two-day lag), U.S. Census Bureau 2017 FIPS Codes
ALABAMA HOMEOWNER ASSISTANCE FUND PLAN 10

AHFA assessed the degrees of delinquencies across the state to identify concentrated areas of 

homeowner needs by county. The below graphic, Exhibit 6, indicates the counties across the state 

where high rates of delinquencies from 30 days to foreclosures occurred. Delinquency rates were 

highest in the following counties: Montgomery, Autauga, Elmore, Tuscaloosa, Shelby, St. Clair, 

Blount, Morgan, Madison, and Limestone. 

EXHIBIT 6 DELINQUENCY RATES BY COUNTY
ALABAMA HOMEOWNER ASSISTANCE FUND PLAN 11

AHFA analyzed information for 26,441 loans as the total state need based on ACS data.

Additionally, the state assessed the data as it relates to homeowners with household incomes less 

than 150% AMI based on the median household size of three (3) persons in owner-occupied 

dwelling units.

17 AHFA further segmented this population into four (4) target populations: 

1. Homeowners with incomes less than 100% AMI (not categorized as socially 

disadvantaged).

2. Socially disadvantaged homeowners with incomes less than 100% AMI.

3. Socially disadvantaged homeowners with incomes between 100% AMI and 150% AMI; 

and

4. Homeowners with incomes between 100% AMI and 150% AMI (not categorized as socially 

disadvantaged).

Of the total 26,441 troubled loans, AHFA determined that approximately 19,283 loans fit into one 

of the four target populations.

18 Exhibit 7 below shows the breakdown of target populations.19

EXHIBIT 7

Target Populations Loan Count 

Less than 100% AMI (Not Socially Disadvantaged) 8,154

Less than 100% AMI & Socially Disadvantaged 6,681 

100% - 150% AMI & Socially Disadvantaged 2,003 

100% - 150% AMI (Not Socially Disadvantaged) 2,445 

Potentially Eligible 19,283 

17 Area median income varies based on location and household size. ACS data includes income ranges 

for tract levels but does not include income ranges per household size. Our analysis used the 3-person 

income limits to estimate the percentage of AMI for households in the ACS data. 18 Target populations were determined based on US Treasury guidance. Our analysis compared 

household income ranges from 2019 ACS data by county to determine the percent of owner-occupied 

households that were equal to or less than 150% of AMI for a 3-person household to obtain the number of 

loans that could be potentially eligible based on income level. Our analysis further segmented all loans 

equal to or less than 150% AMI into the loans equal to or less than 100% AMI. Our analysis applied this 

population of loans by income levels to the percentages of homeowners for each county to determine 

loans included within the socially disadvantaged target groups for 100% - 150% AMI and equal to or less 

than 100% AMI. 19 U.S. Census Bureau American Community Survey (ACS) 2015-2019 5-year estimates, Tables 

B19013B, B19013C, B19013D, B19013E, B19013F, B19013G, B19013H, B19013I, B19049, B19053, 

B25009, B25010, B19019, December 2020
ALABAMA HOMEOWNER ASSISTANCE FUND PLAN 12

Exhibit 8 shows the makeup of the 19,283 potentially eligible homeowners segmented by income 

and socially disadvantaged target populations. Of the total state need of 26,441 loans, 73 percent 

are potentially eligible for assistance. 

Each targeted population has 

been mapped to show the 

geographic concentration. The 

first target population is 

homeowners who are not 

categorized as socially 

disadvantaged but have income 

less than 100% of AMI. Exhibit 9

outlines the concentrated 

counties within the state where 

homeowners in this target 

population are located. 

Delinquency rates were highest 

in Jefferson, Madison, 

Montgomery, and Mobile 

counties with upwards of 25 

percent delinquency rates. 

EXHIBIT 8 TARGET POPULATIONS

EXHIBIT 9 HOMEOWNERS WITH INCOME 

LESS THAN 100% AMI
ALABAMA HOMEOWNER ASSISTANCE FUND PLAN 13

AHFA determined the target population for homeowners with income equal to or less than 100% 

AMI (based on ACS 2019 data) to assess the need of delinquent loan payment amounts. Exhibit 

10 indicates the breakdown of homeowners equal to or less than 100% AMI. Within the total

19,283 potentially eligible loans, 8,154 are included within this target group. 

EXHIBIT 10

INCOME LEVELS LESS THAN 100% AMI 

Loans Dollar Amount 

30 and 60 days past due 1,075 $ 12,892,093

90+ days past due 6,776 $ 77,980,913

Foreclosures 303 $ 1,819,146

Total 8,154 $ 92,692,152 

Exhibit 11 below depicts potentially eligible homeowners who fall under socially disadvantaged as well 

as income less than 100% of AMI. Counties holding the highest degrees of delinquencies are Jefferson, 

Madison, Montgomery, and Mobile with delinquency rates from 17 percent up to 34 percent.

SOCIALLY DISADVANTAGED

HOMEOWNERS WITH INCOME

LESS THAN 100% AMI

EXHIBIT 11 
ALABAMA HOMEOWNER ASSISTANCE FUND PLAN 14

AHFA determined the target population of socially disadvantaged homeowners with income less 

than 100% AMI (based on ACS 2019 data) to assess the need of delinquent loan payment 

amounts. Exhibit 12 indicates the breakdown of socially disadvantaged homeowners with incomes 

equal to or less than 100% AMI. Within the total 19,283 potentially eligible loans, 6,681 loans are 

included within this target group. 

EXHIBIT 12

INCOME LEVELS 100% AMI AND LOWER 

Loans Dollar Amount 

30 and 60 days past due 543 $ 6,507,576

90+ days past due 5,985 $ 77,748,549

Foreclosures 153 $ 918,255

Total 6,681 $ 85,174,380 

The third target population to 

assess is the homeowners who 

are classified as socially 

disadvantaged and have 

incomes between 100% - 150% 

of AMI. AHFA determined the 

income levels (based on ACS 

2019 data) and overlayed 

demographic information of

these homeowners to 

determine who would be 

categorized as socially 

disadvantaged. Exhibit 13

outlines the counties within the 

state that show the degrees of 

need for socially disadvantaged 

homeowners with income levels 

between 100% - 150% AMI.

Jefferson County has the 

highest degree of need in the 

state with 23 other counties that 

have up to 13 percent 

delinquency rates. 

SOCIALLY DISADVANTAGED

HOMEOWNERS WITH INCOME

LESS THAN 150% AMI

EXHIBIT 13 
ALABAMA HOMEOWNER ASSISTANCE FUND PLAN 15

AHFA determined the target population for socially disadvantaged homeowners with income 

between 100% - 150% AMI (based on ACS 2019 data) to assess the need of delinquent loan 

payment amounts. Exhibit 14 indicates the breakdown of need for socially disadvantaged 

homeowners between 100% - 150% AMI. Within the total 19,283 potentially eligible loans, 2,003 

loans are included within this target group.

EXHIBIT 14

INCOME LEVELS 100% - 150% AMI 

Loans Dollar Amount 

30 and 60 days past due 163 $ 1,950,838

90+ days past due 1,794 $ 23,307,428

Foreclosures 46 $ 275,274

Total Need 2,003 $ 25,533,540 

The fourth target 

population to assess is the 

homeowners with incomes 

between 100% - 150% AMI

(based on ACS 2019) but 

are not classified as 

socially disadvantaged. 

Exhibit 15 outlines the 

counties within the state 

that show the degrees of 

need for homeowners with 

income levels between 

100% - 150% AMI.

Jefferson, Madison, and 

Shelby counties indicate 

the highest levels of 

delinquencies in this group 

of upwards of 15 percent.

Homeowners with Income

Less than 150% AMI EXHIBIT 15 
ALABAMA HOMEOWNER ASSISTANCE FUND PLAN 16

AHFA determined the target population for homeowners with income between 100% - 150% AMI 

(based on ACS 2019 data) to assess the need of delinquent loan payment amounts. Exhibit 16

indicates the breakdown of need for homeowners between 100% - 150% AMI. Within the total 

19,283 potentially eligible loans, 2,445 loans are included within this target group.

EXHIBIT 16

INCOME LEVELS 100% - 150% AMI 

Loans Dollar Amount 

30 and 60 days past due 322 $ 3,864,786

90+ days past due 2,032 $ 23,377,086

Foreclosures 91 $ 545,343

Total 2,445 $ 27,787,215 

Based on the preceding data analysis, AHFA has considered 8,684 socially disadvantaged 

homeowners less than 150% AMI as this population experienced the highest employment income 

loss during the pandemic. Additionally, within the total 19,283 potentially eligible loans, AHFA 

identified 10,599 delinquent homeowners not categorized as socially disadvantaged with income 

levels less than 150% AMI.

2.2 PUBLIC PARTICIPATION AND COMMUNITY ENGAGEMENT

Public participation for the proposed HAF plan will be presented for review and comment in a 

public hearing format and direct solicitation from organizations that primarily serve low-, 

moderate-income households, members of groups that have been subjected to racial or ethnic 

prejudice or cultural bias within American society, residents of majority-minority Census tracts, 

Indian Reservations, persistent poverty counties and individuals with Limited English Proficiency. 

The public hearing will be in-person, and will be conducted in a location, format, and time-of-day

that are reasonably accessible to all citizens (particularly low-income and moderate-income 

citizens). Elected officials, public agencies, community groups, and interested parties will be 

notified of such public hearing(s) via the publication of a notice in a newspaper of general 

circulation within the state of Alabama, by the posting of a notice on the AHFA website, email 

message(s) that are sent to interested parties, or by such other manner(s) as may be requested 

or required. A two (2) week public notice period will be given for such a public hearing, and a 

public comment period that may last for a minimum period of five (5) days to a maximum period 

of thirty (30) days will be provided after the conclusion of the public hearing. 

To supplement the public hearing, AHFA has already or will directly solicit feedback from HUD 

housing counseling agencies, legal assistance organizations, local and tribal governments, and 

homeowner-related trade organizations. The draft HAF will be posted, and these organizations will 
ALABAMA HOMEOWNER ASSISTANCE FUND PLAN 17

be given an opportunity to participate by sending comments directly to AHFA and/or attending 

and commenting during the public hearing. 

AHFA has directly engaged the following organizations:

• HUD Approved Housing Counseling Agencies, such as:

- Community Service Programs of West Alabama

- Legal Services of Alabama

- Community Action Partnership of Huntsville/Limestone & Madison Counties

- Center for Fair Housing

• Association of County Commissions of Alabama

• Alabama League of Municipalities

• The Alabama Indian Affairs Commission

• Alabama Association of Habitat for Humanity Affiliates

The draft HAF plan will be available to those individuals with Limited English Proficiency and for 

those with a disability. To achieve this goal, AHFA will post the plan in English, Spanish, Korean 

and in an Americans with Disabilities Act (“ADA”) accessible format. 
ALABAMA HOMEOWNER ASSISTANCE FUND PLAN 18

Program Design

3.1 PROGRAM STRUCTURE

AHFA will administer the HAF plan as Mortgage Assistance Alabama (“MAA”). The program will

provide financial assistance for 100 percent of an eligible homeowner’s delinquent mortgage 

payments, a COVID-19 related forbearance, and all other mortgage-related expenses (including 

subordinate liens, if applicable), and up to 12-months of future mortgage payment assistance

during the time of their eligibility, all subject to a cap (“Program Cap”) of $50,000. The Program 

also provides funding to assist homeowners with loan modifications and lien extinguishments. The 

qualifying hardship must have occurred after January 21, 2020.

Program Cap: 

Based on historical performance of the Hardest Hit program in the state of Alabama, AHFA 

determined that the participation rate of applicants was 24% of all eligible homeowners. Taking 

this rate of participation from Hardest Hit into consideration, AHFA determined that setting 

$50,000 as the Program Cap will allow the program to best serve eligible borrowers.

The MAA program will consist of two components – Mortgage Payment Assistance, and Loan 

Modification, each of which is described further below. 

1) MORTGAGE PAYMENT ASSISTANCE:

The Mortgage Payment Assistance program is available to eligible homeowners who have a 

qualifying Financial Hardship, and/or have a COVID-19 related forbearance. 

MAA will provide a single payment to a homeowner’s servicer(s) to bring the homeowner current 

on his or her delinquent mortgage(s) or payoff a COVID-19 related forbearance. The initial 

payment must fully reinstate the homeowner’s account or pay off the partial claim. If the total 

amount needed to bring the homeowner current or pay off the partial claim exceeds the Program

Cap, the homeowner must provide the necessary shortfall amount, if acceptable to the loan 

servicer. Once the homeowner is brought current or the partial claim is paid off, MAA may provide 

monthly mortgage payments to the homeowner’s servicer(s) including principal, interest, and 

escrow expenses for up to 12 months. However, total assistance for the homeowner may not 

exceed the Program Cap. 

3
ALABAMA HOMEOWNER ASSISTANCE FUND PLAN 19

Homeowners who do not have a mortgage or are not past due on their mortgage payments may 

be eligible if they have experienced a Financial Hardship. MAA may provide monthly mortgage 

payments to the homeowner’s servicer(s) including principal, interest, and escrow expenses for 

up to 12 months. However, total assistance for the homeowner may not exceed the Program Cap.

For homeowners in active foreclosure, legal services will be provided if legal representation has 

not already been retained. Legal and counseling services will not count towards an Applicant’s

overall program cap award amount. 

2) LOAN MODIFICATION PROGRAM:

The Loan Modification Program is available for homeowners who have an eligible Financial 

Hardship. 

The Loan Modification Program will provide funds to assist homeowners to obtain a loan 

modification of their mortgage loan or to extinguish the first mortgage. Homeowners eligible for 

lien extinguishment under the Loan Modification Program must be on a fixed income. A one-time 

disbursement of funds, not to exceed the Program Cap, will be made to the mortgage servicer to 

recast the loan, fill a financial gap that limits a homeowner’s eligibility for a loan modification, or to 

extinguish the first mortgage lien.

Program Exclusions: 

The following items represent program exclusions for both the Mortgage Payment Assistance 

program and the Loan Modification program:

1) Mortgage loans on second homes, vacant properties, or investment properties.

2) Home Affordable Modification Program (HAMP) trial period payments; and

3) Homeowners who are actively participating in another federally funded mortgage 

assistance program administered by a local housing authority, municipality, or other 

authorized agency.

The MAA program will not offer utility assistance, such as electric, gas, water, or internet, due to 

existing assistance programs serving low-, and moderate-income and elderly households in the 

state of Alabama. Instead, the MAA program will focus the limited HAF funding to provide financial 

assistance to bring homeowners current on their mortgage and stabilize their housing.
ALABAMA HOMEOWNER ASSISTANCE FUND PLAN 20

For residents in need of utility assistance, below is a non-exhaustive list of relief programs: 

1. Alabama Low-Income High Energy Assistance Program (LIHEAP) – This program assists 

low-income Alabama residents with the high cost of home energy. Funding is provided 

from the Low-Income Home Energy Assistance Program (LIHEAP) block grant through the 

U.S. Department of Health and Human Services.

2. Project SHARE - A program in partnership with the Salvation Army, Project SHARE helps 

pay the wintertime energy bills of low-income Alabamians who are age 60 or older and/or 

disabled. During the summer, people with medical emergencies also may be assisted, if 

funds are available.

3. The Alabama Business Charitable Trust Fund - Alabama Power stockholders created the 

nonprofit ABC Trust in 1992 to supplement energy assistance efforts. The trust works with 

local community action agencies to help cover the cost of heating and cooling for lowincome families and those struggling with temporary financial problems.

4. Community Action Association of Alabama - Represents the twenty (2) community action 

agencies that provide social services to low- and moderate-income families in all 67 

counties of the state of Alabama.

3.2 CONTINUED ASSESSMENT OF HOMEOWNER NEEDS

The MAA program will initially target HAF funds to bring eligible homeowners current on their 

mortgage payments inclusive of principle, interest, and escrow (taxes and insurance, if 

applicable), and stabilize housing. Although this is the primary focus of the program, AHFA 

recognizes there are additional homeowner needs throughout the state, therefore, during the first 

year of the program AHFA will monitor program performance, review additional data as it becomes 

available and continue to assess the needs of Alabama households. 

Continued homeowner assessment will examine needs for:

1. Payment assistance for delinquent property taxes

2. Payment assistance for homeowner, flood, and mortgage insurance

3. Payment assistance for homeowner association fees, liens, condominium association fess 

or common charges

4. Homeowner Displacement Prevention, including home repairs, overcrowding alleviation

and title clearance

5. Reverse Mortgage Assistance

At the conclusion of additional homeowner needs assessments, and the availability of funds, AHFA

will determine the addition or subtraction of program design elements. 
ALABAMA HOMEOWNER ASSISTANCE FUND PLAN 21

3.3 ELIGIBILITY REQUIREMENTS

Pursuant to Treasury guidelines, AHFA will assess the eligibility of all applicants based on the 

prescribed requirements below. 

Homeowner Eligibility 

To qualify as an eligible homeowner, the homeowner must:

1. Provide written attestation to having experienced a Financial Hardship, and describe the 

nature of the Financial Hardship (for example, job loss, reduction in income, or increased 

costs due to healthcare or the need to care for a family member); and 

2. Have a total household income less than 150% AMI as determined by HUD. 

Mortgage Eligibility 

To qualify as an eligible mortgage, the mortgage must be a:

1. First Mortgage

2. Second Mortgage

3. Loan Secured by Manufactured Housing (Real Estate or Dwelling)

4. Contracts for Deed or Land Contract

Income Determination and Verification Requirements

For the purposes of determining income eligibility, AHFA will use HUD’s definition of “annual 

income” as defined in 24 CFR §5.609. 

AHFA will utilize one of two approaches for a homeowner’s income eligibility determination:

1. Written attestation together with supporting documentation. The homeowner will provide 

a written attestation as to household income together with supporting documentation of 

income including, but not limited to paystubs, W-2s, or other wage statements, IRS Forms 

(1040, 1065, 1099), tax filings, depository institution statements demonstrating regular 

income, or a written attestation from an employer; or

2. Written attestation plus a reasonable fact-specific proxy for household income. The 

homeowner will provide a written attestation as to household income, and AHFA will use 

a proxy for the homeowner’s income verification. If the household is in a census tract with 

any of the following distress and/or low-income designations, the household will be 

presumed to meet income verification requirements:

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

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

unemployment.

c. HUD designations of Racial and/or Ethnic Areas of Concentrated Poverty; or
ALABAMA HOMEOWNER ASSISTANCE FUND PLAN 22

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

Tax Credit (“LIHTC”) Program.

AHFA may provide waivers or exceptions to these documentation requirements, as reasonably 

necessary, to accommodate extenuating circumstances, such as disabilities, practical challenges 

related to the pandemic or a lack of technological access by homeowners when alternative 

documentation or income verification is not available. AHFA will make the required income 

determination based on alternative documentation. 

3.4 TARGETING AND PRIORITIZATION

AHFA will target and prioritize funding to the following populations through the allocation of the 

budget for each group. AHFA will assign 60 percent of the program budget for applications where 

household income is less than 100% of AMI. AHFA will prioritize the remaining percentage of the 

program budget for applications where:

1. Household income is greater than 100% of AMI but less than 150% AMI and are Socially 

Disadvantaged; or 

2. Have a mortgage from FHA, VA, or USDA.

3.5 APPLICATION PROCESS

A secure portal will be provided for intake of homeowner applications. The portal will allow 

interested homeowners to access and apply on their own, or complete certain portions of the 

application via phone through a call center. AHFA will also support a paper application process 

for those homeowners needing that accommodation. Regardless of the chosen method, each 

applicant will experience a user-friendly and easily digestible application process. AHFA will 

leverage our extensive experience in other housing programs in designing an application to meet 

compliance and eligibility criteria, while working to reduce the documentation burden to the 

applicant, as recommended by Treasury. The application processing team will evaluate and 

review applications as they are submitted. Applicants will be contacted directly should additional 

documentation or explanation be needed to process the application.

3.6 PAYMENT PROCESS

Payments from the MAA program will be made in the form of a grant on behalf of the homeowners 

directly to loan servicers and other entities, depending on the type of expenditure. AHFA plans to 

use the Common Data File (“CDF”) to communicate with servicers and validate the loan 

information. AHFA has significant experience with the CDF from the Hardest Hit Fund (“HHF”) 

program and intends to leverage that experience for the MAA payment process. 
ALABAMA HOMEOWNER ASSISTANCE FUND PLAN 23

3.7 MARKETING AND OUTREACH EFFORTS

AHFA understands that a broad and comprehensive marketing and outreach campaign will be 

necessary to effectively target eligible homeowners across the state. AHFA intends to build and 

maintain a dedicated MAA website and social media presence to disseminate information and 

materials. These resources will be accessible to those homeowners with limited English 

proficiency, such as Spanish, Korean and to those individuals with a disability. To support the 

digital marketing and outreach campaign, AHFA intends to utilize paid and earned media, 

including advertisements on television, radio, print media, as well as direct mail and advertising. 

AHFA will also engage its community partners, such as community development corporations, 

housing counseling agencies, credit union associations and/or trade associations to further 

disseminate information on the MAA program. 

To ensure the MAA program reaches targeted populations, AHFA will take an additional step by 

providing program materials in multiple languages and accessible formats, such as Spanish and 

Korean and formats accessible to those with a disability, conducting additional outreach and 

marketing efforts, such as information dissemination through strategic partnerships, local 

information sessions, mobile or remote intake drives, to the following groups and geographic 

areas:

1. Strategic outreach through partnerships with organizations that have historically served 

low-, and moderate-income populations, and socially disadvantaged populations,

2. Additional outreach to targeted geographic areas, including:

a. Majority-minority Census tracts,

b. Persistent poverty counties, and

c. Indian reservations

3.8 BEST PRACTICES AND COORDINATION WITH HAF PARTICIPANTS

AHFA will leverage its successful experience with the HHF program, in addition to its extensive 

experience administering other affordable housing finance programs for single- and multifamily

housing programs. Additionally, AHFA has been participating in regular coordination conference 

calls with the National Council of State Housing Agencies and other State Housing Finance 

Agencies. 
ALABAMA HOMEOWNER ASSISTANCE FUND PLAN 24

Performance Goals

AHFA will leverage the MAA program funds to reduce the number of mortgages in forbearance,

delinquent and in default, provide mortgage payment assistance, and provide loan modifications

for low-to-moderate income households and socially disadvantaged populations. To measure

these outcomes, AHFA will track performance through the evaluation of households served and 

dollar amount of assistance committed towards the following measures:

Program Design 

Element Metric Goal

Mortgage 

Payment and 

Reinstatement 

Assistance

• Number of homeowners assisted.

o Number of homeowners assisted with 

income less than 100% AMI.

o Number of socially disadvantaged 

homeowners assisted.

• Dollar amount of mortgage payment assistance 

provided.

o Dollar amount provided to homeowners 

with income less than 100% AMI

o Dollar amount provided to socially

disadvantaged homeowners.

• Number of mortgages reinstated

• Dollar amount paid for mortgage reinstatement

• Number of days spent to provide assistance

• Assist 3,000 homeowners

o Assist 1,300 LMI 

homeowners

o Assist 1,400 socially 

disadvantaged

homeowners

• Commit $70M dollars of 

mortgage payment assistance

o $42M dollars to LMI

o $28M dollars to socially 

disadvantaged

• 45 days to provide assistance

Mortgage 

Principal and 

Interest Rate

Reduction 

Assistance

• Number of mortgages refinanced

o Homeowners with income less than 100% 

AMI

o Socially disadvantaged homeowners

• Dollar amount paid for mortgage refinance

o Homeowners with income less than 100% 

AMI

o Socially disadvantaged homeowners

• Assist 1,300 homeowners

o Assist 500 LMI 

homeowners

o Assist 600 socially 

disadvantaged 

homeowners

• Commit $30M dollars to 

refinance mortgages

o $18M for mortgage 

refinancing for 

homeowners with income 

less than 100% AMI

o $12M for mortgage 

refinancing for socially 

disadvantaged 

homeowners

Homeowner 

Displacement 

Prevention 

• Number of mortgages in foreclosure prevented • Prevent 400 homeowner 

foreclosures

The MAA program, utilizing HAF dollars, could reduce the total state homeowner delinquencies 

by up to 27 percent. Additionally, AHFA’s Plan is projected to reduce loan delinquencies for the 

potentially eligible homeowners (based on income requirements) by up to 46 percent. 

4
ALABAMA HOMEOWNER ASSISTANCE FUND PLAN 25

Readiness

Since 1980, AHFA has been creating housing opportunities for low-to-moderate income 

households in Alabama through the affordable financing of single- and multifamily housing. AHFA 

provides capital, technical expertise, builds private and public partnerships, matching AHFA 

resources with those of lenders, builders, local governments, and housing developers throughout 

the state. AHFA has an experienced staff and a history of successfully implementing housing 

programs in collaboration with other Alabama state agencies and external partners. The 

implementation and execution of the MAA program will include a combination of AHFA employees 

and outside contractors. 

5.1 STAFFING AND SYSTEMS 

In addition to its internal staffing, AHFA has engaged HORNE LLP (“HORNE”) and HOTB Software 

Solutions, LLC (“HOTB”) to assist in the program planning and administration. Both HORNE and 

HOTB have been working closely with AHFA to develop the Plan and configure the system to 

prepare for program launch. HORNE will be responsible for certain functions in the program 

administration, while HOTB will provide the system solution for the program, which will be 

CounselorDirect. CounselorDirect will also be used for the pilot program. The call center will utilize 

Five9 system, which is described further below. Staff has been hired and trained for the pilot

program and will remain for the larger program. Additional staff will be trained and dedicated to 

the program prior to the launch of the larger program. 

5.2 PROGRAM ADMINISTRATION

AHFA will utilize staff from within the agency for the underwriting, CDF, and payment processes. 

The staff assigned to these functions have significant and relevant experience administering the 

state’s HHF program, which will provide immediate value to the MAA program. 

HORNE will provide case management staff for the MAA program. HORNE has over 15 years of 

experience in administering federal funding, including relevant experience in administering 

housing programs as well as experience in federal funding related to the coronavirus pandemic. 

With over 1,900 employees, HORNE stands ready to deploy resources immediately and ramp up 

resources as the program needs demand. HORNE has already deployed a team of project 

management and subject matter experts to assist AHFA in development of the Plan and pilot 

program. 

Standard Operating Procedures (“SOPs”) are being finalized for the pilot program. The SOPs for 

the pilot program are the starting point for the larger program. Program Management is actively 

developing the SOPs for the larger program in preparation of training and launch of the program, 

5
ALABAMA HOMEOWNER ASSISTANCE FUND PLAN 26

which will continue to be finalized as additional guidance is provided by Treasury. The team is 

prepared to finalize or modify SOPs quickly based on feedback or comments received from 

Treasury. 

5.3 CALL CENTER

HORNE will manage the call center for the MAA program. Professional, compassionate, and 

empathetic service is a top priority for the call center and for customer service management. A 

turnkey solution, including a robust cloud contact technology – Five9 – has been deployed for the 

program. Launching the call center prior to the commencement of the MAA program allows

potential applicants and interested parties to have early access to program information.

Five9 is a proven technology solution that can route, manage, and provide reporting data for all 

contacts each day. The system’s capacity is only limited by the number of Customer Service 

representatives (“CSR”) answering calls. HORNE has significant experience with Five9 from 

similar programs, allowing the team to use best practices in configuring and launching the solution 

for the MAA program. 

CSRs have received extensive training prior to the call center launch, which included training on 

high quality and empathetic customer service, the Five9 system, and initial information on the 

program. As the program requirements mature, additional training will be provided on the program 

guidelines. The CSRs will also be trained on CounselorDirect prior to launch of the pilot program. 

Staffing levels were determined based on HORNE’s experience in other federally funded

coronavirus relief programs as well as anticipated call volumes. The current staffing model can 

support up to 600 calls per day. The Five9 technology has the capability of tracking call volume 

and anticipating staffing levels based on call volume. The call center manager will be closely 

monitoring the volumes to determine if staffing levels are appropriate to meet the demand.

5.4 APPLICATION PROCESSING

Application processing will be supported by a team of CSRs, case managers, as described above, 

and underwriters. Staffing levels were estimated based on the number of anticipated applications 

but will be scaled to meet the demands of the program as additional data becomes available.

Training for the pilot program is set to begin in early August, which includes training on 

CounselorDirect and SOPs, as well as extensive training on the program details and overall HAF 

guidance released by Treasury. As the program matures and the Plan is approved by Treasury, 

the project management team will work to modify training material, as necessary. Best practices 

from the pilot program as well as other relevant programs, such as HHF, are being used in the 

development of training material. Once the training materials are finalized for the larger program, 
ALABAMA HOMEOWNER ASSISTANCE FUND PLAN 27

the team will go through an additional training for any additions and modifications from the pilot 

program. 

5.5 SYSTEM SOLUTION

AHFA has chosen HOTB as the software provider, utilizing CounselorDirect, for the MAA program 

implementation. Established in 2008, HOTB Software Solutions is the leading software provider 

for HAF programs, Emergency Rental Assistance programs and the HHF. With more than a 

decade of experience, HOTB systems have appropriated more than $6 billion in program 

assistance across 14 state government agencies. Through its digital solution, HOTB facilitates 

online intake, application processing, underwriting, grant award, stakeholder communication, CDF 

automation, cash management, payment processing and reporting. 

CounselorDirect will be used for the Pilot Program. AHFA and HORNE will have received training 

on the operation of the CounselorDirect software for the Pilot Program. Additional training will be 

provided prior to go-live for the additional resources added to the team. Training delivery will be 

provided by CounselorDirect.

5.6 PILOT PROGRAM 

AHFA is currently administering several single- and multifamily affordable housing programs, in 

addition to successfully administering the HHF program. It will leverage this experience and 

knowledge to stand up the MAA Pilot Program. AHFA will monitor throughout the pilot program 

period to determine if any program design modifications are needed. The MAA Pilot Program, 

applying program requirements established for the statewide MAA program, will serve Alabama 

loans currently serviced by AHFA, totaling 26,441 loans. 

CounselorDirect, as described in previous sections, is the system of record for the pilot program. 

As the pilot program continues, we will use best practices to shape the upcoming programs and 

remaining system development. Using CounselorDirect to administer the pilot program allows the 

program administration team to become experts at the system and fine tune policies and 

procedures leading to significant efficiencies for the larger program launch. 
ALABAMA HOMEOWNER ASSISTANCE FUND PLAN 28

Administrative &

Program Budget

Total Program Allocation $ 125,695,705 

Administrative Budget Proposal Percent Amount 

Salaries and benefits 5.08% $ 6,380,000 

Professional services 6.58% $ 8,275,000 

Information Technology & Communications 0.88% $ 1,100,000 

Advertising 0.99% $ 1,250,000 

Buildings, leases & equipment 0.44% $ 550,000 

General and administrative 1.03% $ 1,299,000 

Total Admin Budget 15.00% $ 18,854,000 

Program Design Elements 

Counseling or Educational Services 2.50% $ 3,142,393 

Legal Services 2.50% $ 3,142,393 

Total Counseling or Legal Services 5.00% $ 6,284,786 

Program Design Budget 

Targeting - 100% AMI (less than or equal to) 60.00% $ 75,417,423 

Remaining Program Design Budget 20.00% $ 25,139,497 

Total Program Design Budget 80.00% $ 100,556,920 

6
ALABAMA HOMEOWNER ASSISTANCE FUND PLAN 29