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HAF Grantee Plan - HAFP-0210 -Oregon Housing and Community Services - Extracted 02/24/2022 16:09:56

United States Department of the Treasury

Homeowner Assistance Fund Plan

Submitted by Oregon Housing and Community Services

HAF Grantee Plan Name

HAFP-0210
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HAF Grantee Plan - HAFP-0210 -Oregon Housing and Community Services - Extracted 02/24/2022 16:09:56

United States Department of the Treasury

Homeowner Assistance Fund Plan For Participants 

with Allocations $5 million or Greater

Allocation Amount $5 Million or Greater

Submission Date 12/22/2021 4:42 PM

Total Plan Requested Amount $90,927,920.00

Record Type State

Application Record SLT-0080

HAF Grantee Plan Status (external) Approved
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HAF Grantee Plan - HAFP-0210 -Oregon Housing and Community Services - Extracted 02/24/2022 16:09:56

Homeowner Needs and Community Engagement

What Quantitative Data Has Informed the Participant’s Planning?

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

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

eligible homeowners. 

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

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

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

Yes

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

US Treasury – Treasury provided data, contributed by a number of federal agencies, including

information on mortgage delinquencies and forbearances, breakdowns by demographic factor,

and concentration among mortgage servicers.

Atlanta Fed – Data supplied by the Atlanta Fed, including forbearance, foreclosure, and

delinquency data. The Oregon Needs Analysis only used the forbearance data from this source in

the analysis.

CoreLogic – CoreLogic is a mortgage data company that collects data on mortgages including

delinquencies and foreclosures. Foreclosure and delinquency data were used from this source. 

HUD -Data comes from the CHAS dataset which is data collected from the American

Community Survey that is configured for HUD. Cost Burden and income data in the Needs

Analysis come from the CHAS. Tables 1,8, and 9 were used. Table 1 collects information on race

and income level by tenure. Table 8 collects information on cost burden and income level by

tenure. Table 9 collects information on cost burden and race by tenure. 

Mortgage Servicer and Investor Data – Oregon obtained sample data from several mortgage

servicers and an investor related to Oregon mortgages, forbearances, covid hardships,

delinquencies, foreclosures, and demographics.

Oregon Foreclosure Avoidance Program Data – Oregon reviewed data of homeowners that are

in pre-foreclosure status as determined by servicers that are required to participate in this

state-run program.

Sheriff’s Data – Oregon continues to review foreclosure sale notices posted on the Sheriff’s Sale

website as required under Oregon law. 

Property Tax Delinquency and Foreclosure Data – Oregon reviewed a sampling of property tax

delinquencies and county foreclosure actions obtained from a title company and court filings. 

Community Based Organizations, Housing Counselors, NCSHA, and Housing Attorneys –

Oregon contacted, individually and in groups, housing advocates, a DOJ attorney, and

foreclosure attorneys to ground truth data

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

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

housing finance market?

Yes
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HAF Grantee Plan - HAFP-0210 -Oregon Housing and Community Services - Extracted 02/24/2022 16:09:56

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

Each of the resources cited in the above answer, plus:

The Joint Centers for Housing Studies. (2021). The State of the Nation’s Housing. 

https://www.jchs.harvard.edu/state-nations-housing-2021. This report compiles and analyzes

housing data at the national level to explain housing issues facing the country.

Oregon Housing and Community Services. (2021). Implementing a Regional Housing Analysis

Methodology: Approach, Results, and Initial Recommendations. EcoNorthwest. 

https://www.oregon.gov/ohcs/about-us/Pages/housing-needs.aspx. This report, commissioned by

the Oregon Legislature, explores the regional needs for affordable and available housing across

the state. 

Community Based Organizations, Housing Counselors, NCSHA, and Housing Attorneys –

Oregon contacted, individually and in groups, housing advocates, a DOJ attorney, and

foreclosure attorneys to ground truth data obtained from other sources.

Resources and Targeting Tools – Oregon reviewed Oregon-specific data and resources as well as

national information on the pandemic impacts, homeownership, reinstatement and assistance

options, and targeting methodologies.

Data from the Census Bureau – Data on demographics comes from the American Community

Survey (ACS). Tables B25003A-I from the 5-year estimates, 2015-2019, were used to collect

racial demographic information for homeowners in Oregon.

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

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

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

arrearage or tax foreclosure?

Yes

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

Utility providers: no, Oregon determined there were other utility assistance options, that those

were disbursed differently in a way that would cause confusion and administrative burdens with

HAF, and decided not to begin with a utility assistance option. Therefore, we did not review

utility data.

Tax data: Oregon obtained a report on property tax delinquencies statewide, which could not be

broken out to residential or primary residence levels. Oregon also reviewed a sampling of

property tax delinquencies (back to 2015 to gauge averages) and county foreclosure actions

obtained from a title company and court filings to get an idea of volume and status (these could

be better broken out to estimate residential and primary residence but without certainty). Data

was useful for agency review but not reliable enough for inclusion in the needs analysis.

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

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

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

planning.

Hardest hit fund data: Oregon reviewed data from its HHF programs, including demographic

data, and included some of that data in the HAF Plan. Oregon also reviewed reports on other

states' HHF programs and spoke with other states on national and direct calls about HHF and

Cares Act programs.

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

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

design?

Yes

How Has Community Engagement and Public Participation Informed the

Participant’s Planning?

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

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

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

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

statutory targeting requirements.

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

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

Yes

Provider information

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

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

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

Participant’s jurisdiction.
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HAF Grantee Plan - HAFP-0210 -Oregon Housing and Community Services - Extracted 02/24/2022 16:09:56

Provider Name 

Provider Address 

Provider Website

Provider

Primarily

Serves

LMI

Households

Provider

Addresses

Impact of

Housing

Discrimination

Legal Aid Services of Oregon

520 SW 6th Avenue, Suite 700 ,Portland,Oregon 97204

https://lasoregon.org/

Elemental Law

7805 SW 40th Ave., #19025 ,Portland,Oregon 97280

https://elemental.law/

Oregon Law Center

520 SW 6th Avenue, Suite 700 ,Portland,Oregon 97204

https://oregonlawcenter.org/

Oregon DOJ, Consumer Protection

na ,Salem,Oregon 97301

https://www.doj.state.or.us/consumer-protection/

17 Statewide Homeownership Centers providing housing counseling

Please see list of 17 on next tab ,Statewide,Oregon 97301

http://Conducted engagement through various age...

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

organizations or organizations that serve potentially eligible homeowners?

Yes

Community Information

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

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

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

demographic groups in the Participant’s jurisdiction.
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Organization Name 

Organization Address 

Organization Website

Organization

Primarily

Serves LMI

Households

Provider

Addresses

Impact of

Housing

Discrimination

Condensed public meeting attendance list

Includes homeownership centers, governments, nonprofits, agencies,

Salem, Oregon 97301

http://Please see upload next tab

Oregon Housing Alliance

Monthly HAF presentation to and feedback from homeownership

workgroupOrganization with nearly 100 nonprofit housing members,

Salem, Oregon 97301

https://www.oregonhousingalliance.org/our-members/

Governor's Racial Justice Council

HAF presentation and feedback across subcommittees, Salem, Oregon

97301

https://www.oregon.gov/gov/policy/racial-justic...

Oregon Manufactured Housing Advisory Committee

Solicited program advice related to MH and chattel loans, Salem,

Oregon 97301

http://none

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

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

Yes

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

or published materials?

Yes

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

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

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

Oregon hosted virtual public meetings on June 17th and July 1st to discuss the HAF plan,

Oregon housing data and needs analysis, to ground truth the data and needs analysis with

stakeholders, and to review and receive comment on program planning. The video recordings

were posted online with the slides. HAF introductions and updates were provided to at least

three virtual, public housing council meetings and two OHCS housing partner calls, and the

video recordings were posted. The council videos are accessible to persons with disabilities.

Oregon's draft needs analysis, reinstatement program terms, and payment assistance program

terms were posted, in English only, online, for comment for one week. Due to timing constraints,

Oregon was unable to make the posting accessible to persons with disabilities or individuals

without reliable internet access. Oregon did push the notice with document links out by the HAF

constant contact and by direct email to foreclosure attorneys, a sampling of mortgage servicers,
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the Oregon Bankers Association, NW Credit Union Assoc, Catholic Charities, Assoc of Oregon

Counties, Oregon Assoc of Libraries, Oregon Realtors, Oregon Homebuiders, Oregon Mortgage

Bankers Assoc, Immigrant and Refugee Comm Org, Consulate of Mexico, Hispanic Metro

Chamber of Commerce, and every individual that registered to attend either HAF public

meeting.

How Will the Participant Continue to Assess the Needs of Eligible

Homeowners?

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

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

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

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

homeowners?

Yes

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

Updates to the regular data compiled from various sources on homeowners in Oregon and

nationally. In addition, if servicers or investors were able to provide disaggregated data on their

borrowers in Oregon and nationally: changes in forbearance, reinstatement, loss mitigation, and

foreclosure statistics to see what is working and what can be improved. It would be interesting to

see the same data from each of the HAF participants, even if they are running slightly different

programs. Data on nontraditional lending products: private mortgages, chattel loans,

HUD-owned loans, land sale contracts, etc.
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Program Design

What are the Program Design Elements Through Which the Participant Will

Deliver HAF Assistance to Eligible Homeowners?

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

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

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

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

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

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

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

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

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

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

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

by checking the boxes below.

mortgage payment assistance 

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

or government entity 

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

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

 payment assistance for delinquent property taxes to prevent homeowner tax foreclosures 

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

entities 

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

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

facilitating mortgage interest rate reductions 

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

as defined in 47 CFR 8.1(b) 

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

common charges 

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

a home or assistance to enable households to receive clear title to their properties 
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For each program design element that the Participant will offer, the Participant is required to upload a term

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

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

document.

Title Upload Date

2021.09.29 HAF UST Reinstatement Prog Terms 9/30/2021 5:46 AM

2021.09.29 HAF UST Payment Asst Prog Terms 9/30/2021 5:46 AM

2021.09.29 HAF UST Plan 9/30/2021 12:37 PM

2021.12.22 HAF UST Payment Asst Prog Terms revised 12/22/2021 4:40 PM

HAF public meeting participants 9/30/2021 3:20 PM

2021.12.22 HAF UST Reinstatement Prog Terms revised 12/22/2021 4:40 PM

2021.12.22 Oregon HAF UST repsonse 12/22/2021 4:14 PM

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

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

of this submission?

No

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

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

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

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

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

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

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

submission)

Program

Design

Element

Deviation from sample terms Justification
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HAF Grantee Plan - HAFP-0210 -Oregon Housing and Community Services - Extracted 02/24/2022 16:09:56

Prioritizing

FHA, VA,

USDA, and

revenue bond

borrowers

Oregon is not prioritizing these

borrowers unless they fall within a

different Oregon priority, such as

being at-risk of foreclosure, SDI,

rural, low income (see HAF Plan

pp. 23 & 18-20)

• Oregon is not prioritizing applications to

homeowners who have Federal Housing

Administration (FHA), Department of Veterans

Affairs (VA), or U.S. Department of Agriculture

(UDSA) mortgages or homeowners who have

mortgages made with the proceeds of mortgage

revenue bonds or other mortgage programs that

target low- and moderate-income borrowers.

Oregon understands targeting these loans would

identify income-eligible borrowers. However, these

borrowers also have the greatest number of

investor forbearance, reinstatement, and loss

mitigation options so, as a category of borrowers,

they are less at risk of foreclosure and

displacement. If these borrowers fall into one of

Oregon’s other priority categories, such as active

foreclosure, they will be prioritized. Further,

Oregon is not precluding these borrowers from

applying and receiving assistance. We feel that this

decision furthers the Treasury guidance and sample

terms’ goal of not replacing other available loss

mitigation resources. Where there is potential

conflict between this priority encouragement and

Treasury’s desire to supplement – not replace –

other loss mitigation, we decided this approach

furthers the objectives of HAF and will still

prioritize those borrowers if there are no other loss

mitigation options (placing them in the at-risk of

foreclosure priority category).

Reservation

of funds for

rural

homeowners

While not a deviation, it is an

addition to reserve a proportionate

amount for assistance to rural

Oregon homeowners

• Oregon’s intention to reserve proportionate

program funds for rural homeowners does not

deviate from Treasury guidance or sample terms,

which are silent on the rural assistance

prioritization. However, the Treasury guidance

encourages focus on rural communities through

prioritizing USDA loans and in crafting targeting

and performance goals. Oregon believes this

reservation of assistance, described as a

prioritization category in the program terms,

furthers the objectives of HAF
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HAF Grantee Plan - HAFP-0210 -Oregon Housing and Community Services - Extracted 02/24/2022 16:09:56

Payment of

certain

attorney fees,

collection

costs, charges

not actually

paid

Treasury’s sample terms permit

(“may” but not “shall”) payment of

“reasonably required legal fees” and

property charges. Oregon’s terms

take the inverse approach,

excluding attorney fees, collection

costs, and charges not actually paid

to third parties without

authorization under the program

manuals.

For pandemic-impacted borrowers, Oregon’s

foreclosure moratorium prohibited not only

foreclosures but the assessment of late fees and

other charges, which implies that legal or

collections costs would not be warranted.

Therefore, Oregon plans to craft manuals that more

specifically lay out when certain fees, legal fees, or

collection fees were “reasonably required” and will

be paid. Oregon may also make exceptions where

this rule increases the risk of foreclosure to an

otherwise qualified borrower. Oregon believes this

furthers the purpose of the statement in Treasury’s

sample terms while allowing Oregon to determine

how that statement is placed into practice.

Designating

certain

unoccupied

(vacant)

properties

eligible

By Oregon's reading, providing

assistance for a property that is not

currently occupied as a borrower’s

primary residence is allowed under

the guidance and sample terms.

Both Treasury guidance and the

sample terms limit assistance to a

homeowner’s primary residence.

The Treasury’s payment assistance

sample terms expressly define

“primary residence” to include “a

dwelling to be made habitable so it

may serve as the homeowner’s

primary residence.” This definition

focuses on the homeowner’s

intention rather than the current

status of the property. Oregon’s

interpretation is not prohibited

elsewhere: the definition if

mortgage is tied to the definition of

dwelling, which “means any

building, structure, or portion

thereof that is occupied as, or

designed or intended for occupancy

as, a residence by one or more

individuals.” (emphasis added).

Again, current occupancy is not a

requirement if the intention is for

the property to be a homeowner’s

primary residence.

In Oregon vacant and abandoned land or homes are

ineligible unless the vacancy is because of a

physical hazard event, casualty loss, or natural

disaster. This provision shifts relevant properties

into the eligible category. But in order for the

vacant property (or unit) to be eligible, Oregon

requires that – at the time of mortgage origination

and homeowner displacement – the property was

the homeowner’s primary residence. Oregon’s

program terms categorize second home, vacation

homes, and investment property that is not a

primary residence as ineligible property. The

program terms will further clarify how to make

these determinations when the triggering events

have occurred. This will help Oregon meet

homeowner needs identified in the planning

process.
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HAF Grantee Plan - HAFP-0210 -Oregon Housing and Community Services - Extracted 02/24/2022 16:09:56

Fast tracking

applications

for

homeowners

displaced by

natural

disasters

While not a deviation, within each

of the other categories of applicants

and prioritizations, Oregon plans to

fast track applicants who

experienced both a qualifying

coronavirus pandemic-related

financial hardship and loss or

displacement from their homes

because of natural disasters

We feel this furthers the objectives of HAF – as

these homeowners are otherwise qualified – and

meets an urgent and ongoing Oregon homeowner

need that was raised repeatedly in our stakeholder

and public outreach. Oregon’s “prioritization” by

fast tracking homeowners displaced as a result of

natural disaster within each other prioritization

category or within the general pool of applicants.

This is a narrower category of borrowers than in

the first change: just those displaced as a result of

natural disasters. OHCS believes fast tracking

these borrowers is appropriate given the

circumstances, the borrower need, and the strong

advocacy and support we received in the

stakeholder and public engagement phases of HAF

program development. For these reasons, we

believe these deviations from other states – but not

Treasury guidance or the sample terms, which are

silent – furthers both HAF and Oregon

homeowners assistance objectives.

Reinstatement

requirement

to exhaust

other loss

mitigation

options

The sample terms state that HAF

funds will only be used to

supplement other loss mitigation

options or where they are essential

for a homeowner to qualify for the

other loss mitigation options.

Oregon did not include this

requirement in its reinstatement

terms .

Oregon law and CFPB rule require servicers to

reach out to borrowers that self-identified

coronavirus hardships (and sometimes those that

did not) about resolution options. Oregon does plan

to ask the applicant to attest that they have sought

servicer loss mitigation options but does not plan

to require proof of application or a denial notice.

Instead, Oregon has included language in its terms

encouraging servicers and other recipients to

negotiate funding gap resolutions with servicer loss

mitigation options. In addition, Oregon’s servicer

collaboration agreements encourage servicers to

work with borrowers on funding gap resolutions

and other loss mitigation options. We believe this

meets the intended Treasury goal using an

alternative method.
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HAF Grantee Plan - HAFP-0210 -Oregon Housing and Community Services - Extracted 02/24/2022 16:09:56

Requirement

to exhaust all

forbearance

options

(payment

assistance)

Sample payment assistance terms

require borrowers to exhaust all

other forbearance options first.

Oregon will not require borrowers to exhaust all

other forbearance options. We received feedback

that to do so may unnecessarily increase arrears.

We also learned that some servicers are requesting

and granting forbearances beyond the covid

forbearances. If traditional forbearance options are

limited under loan terms, this program rule would

require borrowers to use up all possible

forbearance options for the loan. It could also

cause servicers to term limit forbearance options

with unintended consequences for other borrowers.

In addition, the Stabilization Track of the Forward

Payment Assistance Program does not require an

ongoing financial hardship so such a requirement

would preclude assistance. Finally, practically,

Oregon’s Forward Payment Assistance Program

will open nearly two years after the hardship date

when most borrowers will have exhausted their

other forbearance options. Oregon believes this

deviation is reasonable to operate the Stabilization

Track (see HAF Plan pp.25-26) and in light of the

circumstances and tailored program terms.

Income

eligibility in

Oregon's

payment

assistance

program

Treasury sets general eligibility at

or below 150% AMI or 100% US

median, but with a requirement to

provide 60% to 100% AMI or

below, or 100% US median or

below. This implies the programs

should follow the same or similar

approach.

• Oregon constrained eligibility for this program to

homeowners with income at or below 100% AMI

for two main reasons. First, it will help ensure

Oregon meets the Treasury requirement of

providing 60% of assistance to homeowners at this

income level, doing so in a more administratively

feasible way. Second, we believe low-income

homeowners have a greater need for payment

assistance because they are more likely to be

adversely cost burdened and because unemployed

or underemployed homeowners will have lower

incomes by virtue of their change in income from

pre-pandemic levels.
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Payment

assistance

requirement

of a

continuing

hardship

In addition to a continuing hardship

track of the payment assistance

program, Oregon proposes to

operate a stabilization track for

Eligible Homeowners that do not

qualify for the Hardship Track may

qualify for the Stabilization Track

to increase long-term housing

stability. OHCS will not exceed

three months of payment assistance,

not to exceed a total of $3,750 per

household. To qualify for this track,

households must be cost burdened

by paying more than 35% of their

household income toward housing

(Eligible Costs). There is no

requirement of a continuing

hardship. Please see the HAF Plan

pp.25-26.

Oregon’s needs analysis and stakeholder and

public engagement directly influenced the design

of the stabilization track, which also further the

HAF objectives. Low-income borrowers that are

cost burdened will have limited servicer loss

mitigation options. For some borrowers, housing

cost burden will be the result of a job change or

income loss and may constitute a pandemic-related

qualifying financial hardship. For borrowers that

were cost burdened prior to the pandemic, suffered

a qualifying hardship, but do not have an ongoing

hardship, the Stabilization Track will help increase

their housing and financial stability, pay down

other debt, or rebuild emergency savings. Further,

if borrowers qualify for this track, they will qualify

for Oregon's reinstatement program even if they

cannot afford their mortgages due to the cost

burden. For this tailored track, OHCS believes this

deviation furthers the HAF objectives and it was

strongly encouraged in Oregon’s needs analysis

and engagement.

Documentation of Homeowner Income

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

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

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

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

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

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

homeowner income.

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

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

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

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

Yes

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

Income demographics based upon geographical area, such as zip code or census track as taken

from one or more trusted sources. Income information based upon review and approval of other

assistance programs, such as unemployment benefits (Oregon is investigating other benefits

providers we might partner with). Oregon's program manuals will deal with these options and

parameters of use of the proxies.

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

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

practical challenges related to the pandemic, or a lack of technological access by homeowners; in these cases,
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the HAF participant is still responsible for making the required determination regarding household income

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

exceptions?

Yes

Eligible Mortgage Types

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

Participant’s program design elements.

 First Mortgages 

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

Proprietary Reverse Mortgages) 

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

interest in a dwelling) 

 Second Mortgages 

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

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

explain the exclusion.

N/A

How Will the Participant Target HAF Resources Consistent with Statutory

Requirements? 

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

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

resources for targeted households, including by offering multiple intake formats, engaging with nonprofit

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

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

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

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

Defining Socially Disadvantaged Individual

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

disadvantaged individual” as defined in the HAF guidance.

Applicants will have an opportunity to disclose whether they are a SDI on the HAF application.

OHCS will encourage our intake partners to explain SDI status and its role in HAF. In addition,

Oregon plans to identify the indicators in the Treasury definition so that we may more broadly

track those indicators. Oregon will also complete targeted outreach in those geographical areas

and with SDI populations. Similar to the urban institute tool and rental assistance tools, Oregon

developed a prioritization tool to evaluate applications based upon zip code and other fact-based

data, including SDI data elements to help with overall application processing prioritization.
Page 17 of 29

HAF Grantee Plan - HAFP-0210 -Oregon Housing and Community Services - Extracted 02/24/2022 16:09:56

Public Communications

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

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

or social media?

Yes

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

primarily target the following populations:

 Homeowners earning less than 100% of area median income 

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

American society; 

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

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

 homeowners in persistent poverty counties; 

 individual with limited English proficiency 

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

will be undertaken:

Spanish; Chinese; Vietnamese; Russian

Outreach

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

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

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

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

Yes

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

that primarily target the following populations:

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

American society; 

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

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

 homeowners that reside in persistent poverty counties; 

 individual with limited English proficiency. 
Page 18 of 29

HAF Grantee Plan - HAFP-0210 -Oregon Housing and Community Services - Extracted 02/24/2022 16:09:56

Housing Counseling and Legal Services

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

Yes

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

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

HAF programs. 

Provider Name 

Provider Address 

Provider Website

Provider

Primarily

Serves

LMI

Households

Provider

Addresses

Impact of

Housing

Discrimination

Legal Aid Services of Oregon

520 SW 6th Avenue, Suite 700 , Portland, Oregon 97204

https://lasoregon.org/

Oregon Law Center

520 SW Sixth Ave #700 , Portland, Oregon 97204

https://oregonlawhelp.org/

Elemental Law

7805 SW 40th Ave., #19025 , Portland, Oregon 97280

https://elemental.law/

Center for Nonprofit Legal Servcies

225 W Main St. , Medford, Oregon 97501

https://cnpls.org/

Comm Connection of NE Oregon

2802 Adams Avenue , La Grande, Oregon 97850

https://ccno.org/

Dev NW

528 Cottage Street NE, Suite 304 , Portland, Oregon 97301

https://www.devnw.org/

ACCESS

3630 Aviation Way , Medford, Oregon 97504

https://www.accesshelps.org/

NAYA Family Center

5135 NE Columbia Boulevard , Portland, Oregon 97218

https://nayapdx.org/about/contact/

African American Alliance for Homeownership

825 NE 20th Ave, Suite 225 , Portland, Oregon 97232

https://www.aaah.org/
Page 19 of 29

HAF Grantee Plan - HAFP-0210 -Oregon Housing and Community Services - Extracted 02/24/2022 16:09:56

Hacienda

6700 NE Killingsworth St. , Portland, Oregon 97218

https://haciendacdc.org/

Community Action Team

125 North 17th Street , St Helens, Oregon 97051

https://www.cat-team.org/

Neighbor Impact

2303 SW 1st Street , Redmond, Oregon 97756

https://www.neighborimpact.org/

Neighborworks Umpqua

605 SE Kane St. , Roseburg, Oregon 97470

https://www.nwumpqua.org/

Comm Action Program of East Central Oregon

721 SE 3rd St, Suite D , Pendleton, Oregon 97801

https://www.capeco-works.org/

Columbia Cascade Housing Corp

500 East 2nd street. , The Dalles, Oregon 97058

https://www.mid-columbiahousingauthority.org/

Community in Action

915 SW 3rd Avenue , Ontario, Oregon 97914

https://communityinaction.info/

Portland Comm Reinvestment Initiatives

6329 NE Martin Luther King Jr. Blvd , Portland, Oregon 97211

http://pcrihome.org/

Bienestar

448 S. First Ave. Ste 100 , Hillsboro, Oregon 97123

https://www.bienestar-or.org/

Housing Authority of Yamhill County

135 NE Dunn Place , McMinneville, Oregon 97128

https://www.hayc.org/

Open Door Housing Works

34420 SW Tualatin Valley Highway , Hillsboro, Oregon 97123

http://www.odhw.org/eng/

Klamath Housing Authority

1445 Avalon St. , Klamath Falls, Oregon 97603

http://www.klamathhousing.org/

Targeting specific groups of homeowners

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

 have mortgages or mortgage assistance contracts held or backed by the Participant? 
Page 20 of 29

HAF Grantee Plan - HAFP-0210 -Oregon Housing and Community Services - Extracted 02/24/2022 16:09:56

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

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

 have privately held mortgages? 

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

Potentially Eligible Homeowners, Including Those with Limited English

Proficiency or Who are Disabled?

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

including persons with limited English proficiency and those with disabilities.

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

program documents will be made available.

Spanish; Chinese; Vietnamese; Russian

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

accessible to persons with disabilities?

Yes
Page 21 of 29

HAF Grantee Plan - HAFP-0210 -Oregon Housing and Community Services - Extracted 02/24/2022 16:09:56

Performance Goals

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

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

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

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

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

design elements.

Program Design

Element Metric of Success Goal

Mortgage Reinstatement Reduction in 90+ day delinquency

rate

With other available options, reduce

2.6% to pre-pandemic average of 1%

Mortgage Reinstatement Number of homeowners exiting

forbearance into regular payments

Help 1,000 homeowners reinstate with

HAF

Mortgage Payment

Assistance Avoid a foreclosure crisis

With other options, maintain near .4%

statewide average after end of

moratorium

Mortgage Payment

Assistance See reinstatement points Same as reinstatement goals ascomplimentary program

Payment Assistance for

Homeowner’s Insurance

Will be administered as part of the

reinstatement and payment asst

programs

See reinstatement goals

Payment Assistance for

Delinquent Property

Taxes

Will be administered as part of the

reinstatement and payment asst

programs

See reinstatement goals

Mortgage Reinstatement SDI homeownership rates Maintain rate of SDI homeownership

in Oregon

Payment Assistance for

HOA fees or liens

Will be administered as part of the

reinstatement and payment asst

programs

See reinstatement goals

Payment Assistance for

Down Payment Assist.

Loans

Will be administered as part of the

reinstatement and payment asst

programs

See reinstatement goals
Page 22 of 29

HAF Grantee Plan - HAFP-0210 -Oregon Housing and Community Services - Extracted 02/24/2022 16:09:56

Readiness

Staffing, Systems and Contractors 

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

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

Yes

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

Plan?

No

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

design element described in this HAF Plan?

Yes

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

before the Participant first received HAF funds?

No

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

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

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

Yes

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

partners that will conduct program administration?

No

Use of Initial Payment

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

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

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

$0.00

Has the Participant begun accepting applications from homeowners for any HAF-funded programs?
Page 23 of 29

HAF Grantee Plan - HAFP-0210 -Oregon Housing and Community Services - Extracted 02/24/2022 16:09:56

Yes

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

$0.00

How many households have applied for HAF assistance?

5

How many households has the Participant provided with housing counseling or legal services using HAF

funds?

0

How many households has the Participant provided with assistance using HAF funds?

0

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

As of June 30, 2021 Oregon has used initial HAF funds for staff to complete stakeholder and

public engagement, prepare a needs analysis and draft program terms for public comment, and

to take steps to build capacity, research third-party contractors and partners, and to continue

planning a pilot and main programs responsive to Oregon homeowner needs and feedback.

Oregon's pilot opened November 30, 2021, which is phase one targeting the most at-risk

homeowners, prior to the end of Oregon's foreclosure moratorium on December 31, 2021.
Page 24 of 29

HAF Grantee Plan - HAFP-0210 -Oregon Housing and Community Services - Extracted 02/24/2022 16:09:56

Budget

Budgeting of HAF Funds by Program Design Element 

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

design elements, if offered:

Measure Amount

Mortgage Payment Assistance $23,481,376.00

Mortgage Principal Reduction $0.00

Payment Assistance for Homeowner’s Internet Service $0.00

Payment Assistance for HOA fees or liens $5,000,000.00

Payment Assistance for Delinquent Property Taxes $4,000,000.00

Mortgage Reinstatement $40,817,590.00

Facilitate Mortgage Interest Rate Reduction $0.00

Payment Assistance for Homeowner’s Insurance $800,000.00

Payment Assistance for Down Payment Assist. Loans $1,500,000.00

Payment Assistance for Homeowners Utilities $0.00

Other measures to prevent homeowner displacement

Measure Amount

None expected with these programs $0.00

Displacement Prevention Sub-Total $75,598,966.00

Counseling or Legal Services

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

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

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

prevention or displacement.
Page 25 of 29

HAF Grantee Plan - HAFP-0210 -Oregon Housing and Community Services - Extracted 02/24/2022 16:09:56

Specify the Participant’s allocations for the following Amount

Counseling or Educational Services $500,000.00

Legal Services $1,500,000.00

Services Sub-Total $2,000,000.00

Reimbursement of Funds Expended After January 21, 2020

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

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

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

Type of Expense Amount

None expected with these programs $0.00

Reimbursement Sub-Total $0.00

Allocation of Administrative Expenses

Type of Expense Amount

Interstate travel (outreach clinics, seminars, etc.) $300,300.00

Program administration costs (third party data processing, customer service, IT, etc.) $3,675,129.00

Attorney General Legal Fees $20,000.00

Publicity and Publications (eg. marketing, outreach, documentation) $345,000.00

Professional services (interpretation, temporary workers) $225,000.00

Intake assistance (to extent not covered in counseling, education, and legal) $50,000.00

Personal Services (9 FT staff/benefits for 4 years and estimated indirect time allocations

to HAF)

$4,811,070.00

Telecommunications (staff phones) and services (phone conferencing), dues and

subscriptions (software licenses, secure email, domain, efax), equipment $97,216.00

Office space, facilities, equipment, office expenses, taxes, expendable property, and

indirect cost allocations to HAF

$3,017,379.00

Agency Program Costs (lien and satisfaction recording fees) $787,860.00
Page 26 of 29

HAF Grantee Plan - HAFP-0210 -Oregon Housing and Community Services - Extracted 02/24/2022 16:09:56

Administrative Expenses Sub-Total $13,328,954.00

Total Plan Requested Amount $90,927,920.00

Amount Requested Confirmation:

Yes
Page 27 of 29

HAF Grantee Plan - HAFP-0210 -Oregon Housing and Community Services - Extracted 02/24/2022 16:09:56

Contacts

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

reporting, and an additional contact.

Primary Contact

Name: Ryan Vanden Brink

Agency/Office: Oregon Housing and Community Services

Email: ryan.vandenbrink@hcs.oregon.gov

Phone Number: 9717203775

Reporting Contact

Name: Heather Kessinger

Agency/Office: Oregon Housing and Community Servces

Email: heather.kessinger@hcs.oregon.gov

Phone Number: 5039866725

Additional Contact

Name: Cassandra Cooper

Agency/Office: Oregon Housing and Community Services

Email: cassandra.cooper@hcs.oregon.gov

Phone Number: 5039866858

Proprietary or Otherwise Non-Public Information

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

No

If "Yes," please indicate which information or materials are proprietary or otherwise non-public.
Page 28 of 29

HAF Grantee Plan - HAFP-0210 -Oregon Housing and Community Services - Extracted 02/24/2022 16:09:56

Title VI Assurances

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

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

signed copy to this page before submitting the HAF Plan.

Title Upload Date

2021.09.30 OHCS HAF Title VI Assurance 9/30/2021 1:05 PM
Page 29 of 29

HAF Grantee Plan - HAFP-0210 -Oregon Housing and Community Services - Extracted 02/24/2022 16:09:56

Official Certification

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

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

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

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

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

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

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

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

Name of HAF Participant:

Oregon Housing and Community Services

Name and Title of Certifying Official

Name: Ryan Vanden Brink

Title: Assistant Director of Homeowner Assistance Programs

Telephone: 9717203775

Email: ryan.vandenbrink@hcs.oregon.gov