2

HAFP-0040-Vermont

Treasury Feedback for Resubmission of Plan

Please revise the HAF plan by providing a response to the questions below.

Completeness

• Your plan lists Josh Hanford as the Authorized Official, while the original application for HAF

payments was signed by Lindsey Kurrle. To ensure prompt payment upon approval, the

Authorized Official needs to be the same as the signatory on the original application for HAF

payments. If you need to establish a new authorized representative for HAF payments, a

request should be submitted by email to HAF@treasury.gov.

Response: Secretary Lindsay Kurrle will be listed as the Authorizing Official. 

Homeowner Needs and Community Engagement

Data

• No questions.

Community Engagement and Public Participation

• Please provide an update indicating any public comments you have received since you

submitted your HAF Plan, from which organization you received any such comment, and

whether you have responded to the comments.

Response: Since submitting the HAF plan in August, we received comments from communitybased organizations about ways to make the application process user-friendly and accessible for 

Vermont homeowners. Many of these recent comments stem from experiences of organizations 

involved helping applicants to Vermont’s Emergency Rental Assistance Program. 

Specific comments can be grouped into the following categories:

1. General needs (re expected program demands) which do not require response.

• There is a high volume of homeowners already queuing up to use the program 

including those in mobile home parks

• High volume of clients who need help with rental applications are taxing the capacity 

of some community organizations who will likely also serve homeowners through 

this program.

• Travel is needed to assist residents of mobile home parks with their applications.

2. Technical program requests which are under discussion, a planned activity, completed, or 

not planned.

• There is limited access to computers among mobile home park residents, so 

applications must be available and accessible to non-computer users.

• Response: Planned activity -- paper applications are in process of being 

created

• There is a need for a single point of contact regarding the HAP program for 

organizations to use for questions.

• Response: Planned activity.
3

• There is a need for a streamlined application and document upload process so 

organizations can focus on counseling and other assistance.

• Response: Completed.

• The application needs to be available in languages besides English.

• Response: Planned activity.

• There is a need for an online program checklist and guide.

• Response: Planned activity.

• There is a need for training on the application process for community-based 

organizations.

• Response: Planned activity.

• Partners requested an option to test the application and provide feedback.

• Response: Completed.

• Requested meeting with VHFA 3-6 months after launch to provide feedback and 

opportunity to make process improvements. 

• Response: Planned activity

Comments were provided through meetings we had this fall with representatives from the state’s 

HUD-approved housing counseling agencies, community action program agencies, and 

organizations that work directly with underserved homeowners including people with disabilities, 

BIPOC populations and residents of mobile home parks, including:

• Downstreet Housing and Community Development 

• Champlain Valley Office of Economic Opportunity 

• Opportunities Credit Union

• Windham and Windsor Housing Trust

• Neighborworks of Western Vermont

• US Committee for Refugees and Immigrants (USCRI-VT)

• BROC Community Action 

• Vermont Legal Aid

• Champlain Housing Trust 

VHFA has responded to comments from these representatives by revising application questions 

and organization, removing unnecessary questions and adding an 11th language to the options 

available through the web-based application portal. We have also designed a support system for 

agencies who will be helping customers with applications that reflects the suggestions these 

agencies provided this fall, including reimbursement for travel and translation expenses, staff 

time and having a dedicated VHFA staff person (in addition to the general helpline to be provided 

by our HAF program vendor) available for questions from these organizations. We have also 

developed a document checklist and program summary to make available online when the 

program launches. 

Ongoing Assessment of Homeowner Need

• Please explain how the program will address changesin homeowner needs in the coming years.

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

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

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

may have shifted. By confirming HAF usage trends with broader quantitative data sets available through 
4

mortgage servicers, the National Delinquency Survey, the Federal Reserve Bank of Atlanta, Vermont’s 

largest utility providers, and the Census Bureau, we will propose any changes warranted to our HAF plan. 

For example, if the demand for utility assistance through Vermont’s HAF program during the first year falls 

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

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

such as help with home repairs. 

Program Design

• Will there be a method in your HAF program, early in the process of engaging with a household,

to evaluate immediate threats to the housing stability of applicants, which may need to be

addressed under an expedited or prioritized timeline (e.g., HOA liens, tax delinquencies, utility

shut off)?

Response: The application asks homeowners to indicate if they are at risk of losing their home or of

utility shut off within the next 30 days. If they answer “Yes”, their application will be prioritized with 

the intent of keeping them in their home with as minimal utility service interruption as possible. 

• Please describe how your program will utilize housing counselors or legal services to assist

homeownersin evaluating loss mitigation options available for their mortgage. Your description

should include: 

o whether your program will connect homeowners with housing counseling or legal

services early in the process.

o the role housing counseling or legal services providers will play in supporting

homeowners’ efforts at engaging in loss mitigation.

Response: For both legal and housing counseling, the HAF application will describe the potential benefits 

of these services and provide several opportunities throughout the application to request them. This will 

include a section that asks the applicant whether they expect to be able to afford their housing payments 

in the long run, given their expected future income. To the extent that they have concerns about this, the 

application will encourage them request housing counseling. 

Vermont’s HAF program will connect dedicated staff at the Vermont Legal Aid Office of every applicant 

who indicates a need on their application for legal services. Similarly, the program will notify a HUDapproved housing counseling agency when an applicant requests counseling services. As needed, housing 

counselors and Vermont Legal Aid attorneys will support HAF applicant engagement with mortgage 

servicers regarding loss mitigation. 

Vermont’s providers of housing counseling have limited capacity. For this reason, we are also in the process 

of arranging for the option of phone counseling via a national HUD-approved housing counseling provider. 

• How will your program leverage resources available through a loss mitigation process to benefit

eligible homeowners and how will your program avoid using HAF funds in ways that duplicate

relief that available loss mitigation options might provide?

Response: The VT HAF application will advise applicants requesting mortgage assistance of the 

availability of loss mitigation options and ask them to describe their communication with mortgage 

servicers including the status of options the servicer has offered. This information will be used by 

providers of housing counseling and legal services who will facilitate applicant engagement with 
5

mortgage servicers regarding loss mitigation as appropriate. 

• Please explain whatsteps, if any, your program will take to assist the homeowner in determining

whether a HAF-resolution will result in a sustainable monthly payment? 

Response: The VT HAF application will encourage applicants who are uncertain about the affordability of 

their monthly payments in the long run to seek housing counseling and will connect applicants 

requesting counseling with HUD-approved counseling agencies. Vermont’s housing counselors are well 

equipped to help each homeowner they work with to make the adjustments needed to ensure that their 

housing is stable and their monthly housing expenses affordable and sustainable in the long run. 

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

homeowners that HAF will serve?

Response: Since we submitted the draft HAF plan, estimates of the costs of heating fuel have increased 

significantly. The U.S. Energy Information Administration’s short term outlook estimates increased costs 

for northeastern Vermont by 10-40% this winter alone. For this reason, we would like to increase the 

total amount of assistance provided through the VT HAF program from $20,000 to $30,000. This will 

enable the HAF assistance to more adequately cover overdue utility bills for qualified applicants. 

In addition, to help with ongoing expenses, we have added information to the HAP application portal and 

website list of other resources to include Vermont’s seasonal fuel assistance program funded through 

LIHEAP. 

Eligibility

Your programs set $20,000 as the maximum amount of assistance per homeowner. Please 

explain how you determined this amount will be sufficient to resolve housing-related

delinquencies and whether the cap will be sufficient in areas with higher housing costs?

Response: Prior to developing the HAF Plan, we prepared estimates of the amount of assistance needed 

by low- and moderate-income homeowners with financial hardship stemming from the pandemic. For the 

average Vermont homeowner eligible for HAF who needed help in all four assistance areas (mortgage,

property tax, utility and association fees/common charges) the amount of assistance needed totaled an 

estimated $20,000. 

Since that time, we have determined that the amount of assistance needed in 2022-2024 to cover past 

due utility bills, especially home heating fuel costs, is likely to be higher than our original estimates. This 

is based on information on the utility expenses of renters applying to Vermont’s Emergency Rental 

Assistance Program in recent months and the U.S. Energy Information’s short-term outlook estimates 

about likely costs in the coming winter months. For this reason, we plan to raise the total amount of 

assistance cap to $30,000. 

Outreach

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

limited English proficiency.

Response: 98% of Vermont residents speak only English or speak English very well in addition to 

another language. That said, there is a growing population of people with limited English proficiency

in Vermont due to a robust Refugee Resettlement program.
6

Vermont’s HAF program will target outreach and provide access to homeowners with limited English 

proficiency through a multi-pronged approach: (1) bringing in as HAF program affiliates the two 

community-based organizations that most closely serve new Americans in VT: Vermont Association of 

Africans Living in Vermont (AALV) and the U.S. Committee on Refugee and Immigrants (USCRI-VT) who 

will ask ambassadors to share information about the HAF program with LEP communities; (2) building 

a relationship with the Ethiopian Community Development Council branch that just opened in VT; (3) 

translating program marketing materials into the top 10 non-English languages spoken in Vermont

including digital search and display advertising, short videos, and program flyers; (4) translating 

application portal content, paper applications in 10 languages and providing Call Center operators in 

all languages; and (5) monitoring applications to add promotional activities for towns and population 

segments that are under-represented. 

Please explain how the program will provide culturally relevant marketing.

Response: VHFA has started and will continue to obtain regular feedback on HAF marketing approaches 

through its network of 17 community-based organizations serving socially disadvantaged individuals, 

homeowners with limited English proficiency and homeowners with low incomes. In addition to helping 

homeowners with applications, these organizations will use their networks and proven outreach strategies 

to disseminate HAF program information in culturally relevant ways. In addition, VHFA has developed 

connections to several hundred other statewide and local organizations that will use platforms and 

networks tailored to their mission and customers to share HAF program information. 

Prioritization

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

your program prioritize Socially Disadvantaged Individuals? 

Response: Although we plan to launch the program with eligibility up to 150% AMI, we will 

continually monitor the portion of approved grant amounts paid on behalf of applicants above 100% 

AMI. If this reaches 30%, we will reduce affordability to 100% AMI for applicants who are not socially 

disadvantaged as a way of ensuring we will remain within program limits. In addition, applications 

from Socially Disadvantaged Individuals will be prioritized to ensure that grants to these homeowners 

are paid as quickly as possible. 

Performance Goals

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

public.

Response: We will display a live web-based dashboard of program activity and impact metrics on the 

program website. For a similar mortgage assistance program funded with CARES Act funding in 2020 

and 2021, this dashboard was available online and updated weekly. You can see that site here: 

https://www.vhfa.org/partners/initiatives/program-impacts/map

In addition, we will prepare annual reports on the impact of Vermont’s HAF program relative to 

performance goals and community wide trends. The Vermont Agency of Commerce and 

Community Development will also out on Vermont’s progress toward HAF performance goals. 

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

program.
7

Response: 

1. Households assisted by income level (<50% AMI, 50-80% AMI, 80-100% AMI, 100-150% 

AMI) in comparison to homeowner households statewide by income level. 

2. Distribution of households assisted by county relative to distribution of total population of 

homeowners.

3. Portion of households assisted who are BIPOC as compared to portion of all VT BIPOC 

homeowners.

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

Response: We plan to disaggregate metrics by a variety of demographic characteristics including income, 

race, ethnicity, veterans status, age of applicant, household size and property type. 

• Please consider including as an additional metric the number of homeowners

assisted/foreclosures prevented solely through counseling or legal services without payment of

HAF funds to resolve the homeowner’s defaults or delinquencies.

Response: We will add this to our annual HAF report as a distinct metric along with the total number of 

HAF applicants that received housing counseling and legal services. 

Readiness

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

staffing, contractors, etc.

Response: VHFA has chosen a vendor for development of an application portal and application 

management, and we have been working with them to develop systems and processes. VHFA has 

assigned various existing staff members to its Homeowner Assistance Program team and has hired one 

dedicated staff member for the program. Additional staff may be hired as needed. We are actively 

negotiating agreements with outreach partners, legal services, and HUD-approved housing counseling 

agencies. We have met with the state’s largest utility provider to plan out the utility arrearage 

payment process, and have closely followed the national discussions with major servicers and plan to 

adopt the standardized process agreed upon by state housing agencies and loan servicers.

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

launch following approval?

Response: As noted above, VHFA and its vendor have been working on developing an application 

portal and develop systems and processes for managing the program. We expect that we should be 

able to launch within thirty days after approval.

• Please provide updated information about your progress in spending the initial 10% payment

from your jurisdiction’s full allocation and the status of any pilot assistance already offered or

made available to homeowners.

Response: So far, the 10% payment has been used for payments to our vendor for development of 

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

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

purposes. Because VHFA had just completed a round of CARES Act funded mortgage assistance which 
8

closed in June 2021, no pilot program was offered using Homeowner Assistance Fund money to allow 

for the Agency to focus on developing the Homeowner Assistance Program. Additionally, the state 

used CARES Act funds to provide well over $15 million in utility arrearage funding to households and 

businesses through a program that was open through October 2021. 
9

Budget

• Your plan provides a total budget amount of $54,945,864, an amount greater than your full

allocation amount of $50,000,000. Please revise your budget to reflect this allocation amount.

Our records indicate that you have $45,000,000 remaining from your allocation, after deducting

your initial 10% payment.

Mortgage 

reinstatement 

 

18,827,692 

Utilities 

 

10,581,457 

Association fees 

 

4,539,078 

Property taxes 

 

7,168,590 

Subtotal 

 

41,116,817 

Counseling

 

560,000 

Legal Services 

 

821,000 

Subtotal

 

1,381,000 

Admin expenses

 

7,500,000 

Total

 

49,997,817