1

HAFP-0131-Pennsylvania

Treasury Feedback for Resubmission of Plan

Please revise the HAF plan by providing a response to the question(s).

Completeness

• No Questions

Homeowner Needs and Community Engagement

Data

• Please explain how the plan targeting and outreach reflect the data referenced in your plan.

The outreach plan for the Pennsylvania Housing Assistance Fund (PAHAF) includes various communication 

pathways to ensure that low to moderate income, at risk, and socially disadvantaged populations across the

commonwealth are notified of program availability and afforded meaningful access to program resources. Data 

analyses performed during the needs assessment process demonstrated that Pennsylvania homeowners, both with and 

without mortgages, experienced financial distress as a result of the COVID-19 pandemic that threatens housing 

stability. Excerpts from the needs assessment that were particularly informative on the program’s outreach strategy 

include the following:

Applying a combined average mortgage forbearance and delinquency rate [of 10.5% (derived from 

available data sources)] to the population of PA homeowners with incomes below 100% of AMI, 

approximately 28,676 PA owner-occupied households were delinquent and 62,633 were in 

forbearance in the first quarter of 2021. In total, an approximated 91,309 owner-occupied 

households with incomes below 100% of AMI are currently in forbearance or delinquent on their 

mortgages. [PHFA further investigated these data sources to identify] the estimated number of 

households in delinquency and forbearance across different racial and ethnic groups, using 

nationally estimated delinquency and forbearance rates for different racial and ethnic groups.1

[PAGES 14-15]

Additionally, there are ZIP Codes across the Commonwealth with combined 

delinquency/forbearance rates above 10% - from Philadelphia to Scranton, Johnstown, in the 

Southwest and Northwest. The greatest concentrations of ZIP Codes with elevated populations of 

Social Disadvantaged households tend to be clustered in the Southeast (Philadelphia), Northwest 

(Erie), South-Central (Harrisburg and York), Northeast (Monroe), and Pittsburgh areas. Data 

suggests that roughly 36,500 socially disadvantaged homeowners’ mortgages are either in 

forbearance or delinquent. [PAGE 16]

Based on American Community Survey, 2015-2019 data from Integrated Public Use Microdata 

Series (IPUMS), an estimated 935,422 Pennsylvania homeowners are income eligible at 100% of 

AMI and do not currently have a mortgage, including 107,521 socially disadvantaged homeowners. 

Socially disadvantaged homeowners without a mortgage live predominately in Philadelphia (43%), 

Allegheny (8%), Montgomery (7%), and Delaware (7%) counties. Income-eligible Hispanic 

homeowners without a mortgage also commonly live in Berks (9%) and Lehigh (8%) counties. 

[PAGE 16]

Analysis of delinquent property tax and utility data indicated significant need for these services as well. In 

Philadelphia, 2,271 homeowners became newly delinquent on property taxes in 2020, possibly because of COVID1 https://files.consumerfinance.gov/f/documents/cfpb_characteristics-mortgage-borrowers-during-covid-19-

pandemic_report_2021-05.pdf
2

related income losses. In February 2021 there were 814,508 ‘at risk’ accounts, representing about 16% of the 

Pennsylvania population, associated with $852,054,166 in outstanding debt reported by most of the commonwealth’s 

largest utility providers.

Using this information, PHFA has devised the following targeting and outreach approach: 

The PAHAF communications and outreach strategy focuses on the development and successful implementation of the 

PAHAF goals of accessible marketing, mobile intake operations, and leveraging program champions. A targeted 

outreach approach will ensure the Program is highly visible across the Commonwealth to build general awareness of 

the available resources to Pennsylvania homeowners. Our outreach targeting is three-fold – target all eligible 

Pennsylvania homeowners, particularly those who are socially disadvantaged, and at or below 100% AMI. The needs 

assessment data analysis, as described above, informs the geographic targeting activities.

Understanding the rich diversity of Pennsylvanians, PAHAF will ensure that all external facing marketing materials 

and resources are made available in both English and Spanish. Additionally, PAHAF will work with local 

organizations that are deeply connected to racially and ethnically diverse groups to clearly identify additionally 

language and cultural competencies that must be incorporated into our messaging and outreach efforts to increase 

Program reach and accessibility. 

As part of our PAHAF marketing and outreach efforts, our GIS analysts are conducting further research into our 

homeowner data and needs assessment to complete a ZIP Code level targeting map. This map will provide invaluable 

information for media, digital ad targeting, and out of home marketing to focus our efforts on key communities and 

populations. Additionally, PAHAF plans to work hand in hand with nonprofit organizations, faith-based organizations, 

and other local entities that have already established relationships and trust with our target populations. Through 

regular engagement and communication with these local leaders, PAHAF will increase access and visibility to 

homeowners that need PAHAF the most. PAHAF will also be cognizant to adjust outreach strategies and targeting 

accordingly to move resources to communities that need the assistance the most. 

Connecting to elected officials, locally and statewide, PAHAF will become a household name that will be essential in 

building trust and legitimacy. The PAHAF Outreach team will execute a robust paid media campaign that not only 

promotes PAHAF across the Commonwealth, but additionally pinpoints targeted ZIP Codes to increase digital 

targeting and “out of home” advertising to reach Pennsylvanians where they are. 

Program assistance will be made accessible to all through an easy application process. Applicants can apply online or 

by phone, as well as visit a nearby mobile intake site to learn more or receive in-person assistance to complete their 

application for program assistance. For those Pennsylvanians that have limited to no internet access – the PAHAF call 

center, partner organizations and housing counseling agencies and mobile intake sites will allow the Program to 

increase its accessibility and visibility. 

Community Engagement and Public Participation

• Your plan does not highlight your approach to serving low- or moderate-income populations or

addressing housing discrimination. Please explain how the program is confident in its ability to reach

targeted populations.

PAHAF has established the following prioritization scheme in its program policies and procedures.

Because available funding may not be sufficient to meet the needs of all Pennsylvania homeowners, the 

PAHAF program will serve homeowners with the most need first. The following is the order of priority for 

eligible PAHAF applicants:

• Priority 1 - Homeowners with annualized current income of no more than 100% of area median income 

(AMI) for the relevant household size or 100% of the area median of the United States ($79,900) 

whichever is greater and meet the definition of socially disadvantaged.
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• Priority 2 - Homeowners with annualized current income of no more than 100% of area median income 

(AMI) for the relevant household size or 100% of the area median of the United States ($79,900) 

whichever is greater. 

• Priority 3 - Homeowners with annualized current income of no more than 150% of area median income 

(AMI) for the relevant household size and that meet the definition of socially disadvantaged.

• Priority 4 - Homeowners with annualized current income of no more than 150% of area median income 

(AMI) for the relevant household size.

Note that the PAHAF pilot program will first consider applications from Priority 1 through Priority 3 while 

closely monitoring that 60% of the pilot funding falls within Priority 1 and Priority 2. This methodology is 

intended to ensure that the PAHAF program meets minimum Treasury spending requirements. PAHAF will 

not accept applications in Priority 4 until such time that it has been demonstrated that the program can comply 

with the 60% spend threshold for households at or below 100% AMI.

Our PAHAF Outreach team identified key organizations, including state and local social service organizations, that 

regularly engage and interact with low to moderate income populations that would most benefit from PAHAF. By 

developing a robust community partner engagement strategy that further grows PAHAFs network, the Program will 

increase program visibility and access to the commonwealth’s most vulnerable communities. 

PAHAF has also partnered with housing counseling agencies and legal services providers. These entities will assist in 

program outreach and application submission activities. Outreach efforts conducted by these groups are able to 

concentrate on homeowners that have been subject to or homeowner populations that have historically been subject 

to housing discrimination. Fair housing and predatory lending education is a consistent service offering among these 

providers. 

• Please describe any coordination you intend with Tribes or Tribal entities.

PHFA is aware that the Mohegan Tribe of Connecticut and the Poarch Creed Indian Tribe of Alabama have both 

invested significant resources in Pennsylvania. These resources include operation of state-licensed facilities, but do 

not include any Tribal Lands. There are no federally designated Tribes or Tribal Lands in Pennsylvania. 

However, PHFA recognizes that Tribal Nations that receive HAF program funds can provide financial assistance to 

their Tribal Members regardless of the state in which the member lives. To the extent that a Tribal Member of any 

Tribal entity owns his or her home in Pennsylvania, that Tribal Member is eligible to apply for assistance through the 

PAHAF program.

PHFA does note that this could create the potential for duplication of benefits between the PAHAF program and Tribal 

Nation programs. To this end, the PAHAF will request information from all applicants regarding any HAF assistance 

sought from Tribal entities and will institute a subrogation policy to recover any potential duplicative assistance. 

• 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.

No new public comments have been received since submission of the PAHAF Plan. However, the Saves our Home 

Coalition has continued to express concerns that the organization raised prior to submission related to the $30,000 cap 

on assistance. The organization believes this amount is too low. PHFA has addressed the comments and has made 

accommodation through the plan development process to allow for re-evaluation of the effectiveness of the cap and 

possible change in the future should data support such a change.
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Ongoing Assessment of Homeowner Need

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

PHFA conducted a thorough assessment of homeowner need in Pennsylvania as part of the initial HAF Plan 

development. To inform the distribution of resources and to target communities and populations in greatest need, 

PHFA examined demographics, economic conditions, and risk factors for housing instability for the entire 

Commonwealth. With the launch of the pilot program, more tangible data sources are becoming available. PHFA will 

examine applicant population characteristics, as the program progresses, to determine whether homeowner needs are 

being met and are changing over time. PHFA anticipates that applications that fail to meet eligibility requirements 

may be most indicative of areas of opportunity for expanded program services or modification of policy or procedure. 

Further, analysis of the rate of spending in each budget area will provide another key indicator of homeowner need

upon which future program design decisions may be made. If funding is available, Treasury guidance is updated, 

and/or homeowner need is demonstrated, PAHAF may add program design elements, update policies and procedures, 

or modify budget allocations in the future to address changing homeowner needs.

Program Design

• Please explain how the sources of data listed in the section on Homeowner Needs informed theProgram

Design Elements included in your plan.

Key excerpts from the needs assessment are included below to illustrate the level of analysis performed and how the 

results of that study have informed the program’s design elements of mortgage reinstatement, mortgage payment 

assistance, homeownership cost assistance (taxes, fees, insurance), and utility delinquency assistance.

The Commonwealth used a variety of data sets to determine the extent to which various types of 

homeowners may be at risk of default, foreclosure, or housing instability. The following 

combination of public and proprietary data were used to develop estimates of COVID-related 

homeowner needs in Pennsylvania: Home Mortgage Disclosure Act (HMDA) (12 U.S.C §§ 2801-

2811), loan-level data (2007 to 2019), U.S. Census American Community Survey (Census ACS) 5-

Year Estimates (2015-19), PHFA borrower records, Bureau of Labor Statistics’ Local Area 

Unemployment Statistics program (2020 to Q1 2021), ZIP Code-level Mortgage Analytics and 

Performance Dashboard (MAPD) data on loan performance collected and compiled by the private 

research firm Black Knight, LLC. and accessed from the Federal Reserve Bank of Atlanta (2020 to 

Q1 2021)2

, tax delinquency data from Allegheny County (courtesy of the Western Pennsylvania 

Regional Data Center) and the City of Philadelphia (courtesy of OpenDataPhilly), and delinquent 

utility account information from the Pennsylvania Utilities Law Project. [PAGE 3]

These data were analyzed to understand the contemporary volume of homeowners across the 

commonwealth and how homeownership varies across different regions of the commonwealth and 

among different populations. These analyses were developed with a particular focus on estimating 

the total population of PA homeowners who could benefit from support from the HAF related to 

mortgage assistance and other housing related costs such as utilities, taxes, condominium 

association fees, etc. [PAGE 3]

ACS 2015-19 records provide the most reliable way to identify areas in Pennsylvania with high 

populations of low income and Socially Disadvantaged homeowners, both with and without 

mortgages, who may be eligible for assistance under one of the PAHAF programs. Table 4 presents 

the number of owner-occupied homes with and without a mortgage, disaggregated by pre-pandemic 

income and Socially Disadvantaged status. [PAGE 13]

Using the estimated target populations, each population segment was further broken down by their 

vulnerability to foreclosure. Target populations who are the most likely to need assistance may be 

2 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.
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homeowners with a mortgage who are coming out of a forbearance plan; homeowners without a 

mortgage who were unable to pay their real estate tax obligations; homeowners who may be 

delinquent on their home loan; or homeowners in condominiums who are delinquent on association 

fees. [PAGE 13]

Applying a combined average mortgage forbearance and delinquency rate (10.5%) to the population 

of PA homeowners with incomes below 100% of AMI, approximately 28,676 PA owner-occupied 

households were delinquent and 62,633 were in forbearance in the first quarter of 2021. In total, an 

approximated 91,309 owner-occupied households with incomes below 100% of AMI are currently 

in forbearance or delinquent on their mortgages. These data were analyzed for households in 

delinquency and forbearance across different racial and ethnic groups, using nationally estimated 

delinquency and forbearance rates for different racial and ethnic groups. Forbearance rates were 

(and remain) much higher in the Philadelphia (Southeast) and Northeast Regions compared to the 

rest of the commonwealth. [PAGES 14-15]

[Analyzing these data at the ZIP Code level], there are ZIP Codes across the Commonwealth with 

combined delinquency/forbearance rates above 10% - from Philadelphia to Scranton, Johnstown, in 

the Southwest and Northwest. The greatest concentrations of ZIP Codes with elevated populations 

of Social Disadvantaged households tend to be clustered in the Southeast (Philadelphia), Northwest 

(Erie), South-Central (Harrisburg and York), Northeast (Monroe), and Pittsburgh areas. [PAGE 16].

Many Pennsylvania homeowners without mortgages have income losses from the COVID-19 

pandemic that have resulted in property tax arrearages, including many socially disadvantaged 

homeowners. Tax delinquency data from Philadelphia and Allegheny counties suggest that 

homeowners with COVID-related income losses could be thousands of dollars behind on property 

taxes. [PAGE 16]

In Philadelphia, 2,271 homeowners became newly delinquent on property taxes in 2020, possibly 

because of COVID-related income losses. These homeowners were typically about $611 dollars in 

arrears, although the average is almost twice that amount ($1,153). In Allegheny County 700 

homeowners were newly tax delinquent in 2020,3 with a median delinquency arrearage of $1,172 

and average of $1,743. [PAGE 17]

In addition to household need for mortgage assistance and tax arrearages, a great deal of low to 

moderate income households in PA could also benefit from support for utilities arrearages incurred 

due to income losses associated with the COVID-19 pandemic. Accessing reliable data for utility 

arrearages is challenging due to the diverse range of providers, both public and private, across the 

Commonwealth. However, the Pennsylvania Utility Law Project (PULP) collects a range of data 

points from the Commonwealth’s largest utility providers on a semi-annual basis to track ‘at risk’ 

accounts and dollar values of arrearages associated with these accounts. [PAGE 19]

In February 2021 there were 814,508 ‘at risk’ accounts associated with $852,054,166 in outstanding 

debt reported by most of the commonwealth’s largest utility providers to PULP. This represents 

roughly 16% of all PA households. While it is not possible to know which of these delinquent 

accounts are associated with renters and those associated with homeowners, a conservative estimate 

of 10% of the income eligible owner-occupied households in PA in need of utilities assistance would 

represent roughly 182,000 households. Additionally, a recent report from Philadelphia’s 

Community Legal Services and the PA Utility Law Project found that utility delinquencies are 

disproportionately concentrated among socially disadvantaged residents.4 [PAGE 19]

• 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 

3 Not all municipalities in Allegheny County had reported 2020 tax liens by the time of this writing, so this number 

understates the extent of need for property tax assistance there. 4 https://clsphila.org/wp-content/uploads/2021/03/CLS_UtilityReport_20200324.pdf
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an expedited or prioritized timeline (e.g. HOA liens, tax delinquencies, utility shut off)?

The application process is designed to gather information about the applicant’s current housing situation. This includes 

data on the status of mortgage and homeownership costs that can pose an imminent threat to housing stability. The 

program is also providing utility assistance for homeowners with an imminent threat of utility disconnection. Further, 

applicants will be referred to supportive services through housing counseling and/or legal aid service providers.

Practical implementation steps include:

1. Questions in application specifically designed to allow the program to assess applicant mortgage and housing 

cost delinquency statuses.

2. Call center/case management referral to housing counseling and/or legal service providers.

3. Housing counseling/legal services entities are provided access to submit applications on their clients’ behalf.

4. Trigger notification to payees using CDF process by sending the Initial Submission, “I”, record to make 

servicers aware of the application.

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

in evaluating loss mitigation options available for their mortgage. Your descriptionshould include:

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

services early in the process.

A link to housing counselors and legal aid service providers will be available on our website at https://pahaf.org/ to 

help individuals self-select into the resources that are needed. Further, this information is provided to homeowners 

through the application and case management processes—the earliest steps of the whole HAF process.

Additionally, the PAHAF program has developed a referral policy and procedure that allows applicants to enter 

housing counseling and legal services with partner agencies. The referral process includes outcome determinations 

that will allow the program to track services rendered for the assistance provided beyond a successful HAF Application 

some of which include:

• Legal Service Providers (LSP)

o Non-HAF Assistance Obtained 

o Obtained forbearance, loan modification, or other loss mitigation

o Debt/fees avoided

o Bankruptcy discharge obtained

o Client became record owner of property 

o Assistance unable to be obtained

o Assistance with property taxes obtained

o Assistance with utilities obtained

o Assistance with insurance obtained

• Housing counseling

o Households that obtained forbearance or other loss mitigation after receiving Housing Counseling 

Services.

o Households for whom counselor provided assistance with HAF Application 

o Households for whom counselor developed mortgage payment plan.

o Assistance unable to be obtained

o Households that prevented or resolved a mortgage default after receiving Housing Counseling 

Services.

o Households that prevented or resolved a reverse mortgage default after receiving Housing 

Counseling Services.

o Households for whom counselor developed a sustainable household budget through the provision 

of financial management and/or budget services.

o Households for whom counselor developed a budget customized to a client’s current situation.

o Households that gained access to resources to help them improve their housing situation (e.g. utility 
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assistance, taxes, HOA/condominium fees, or insurance etc.) after receiving Housing Counseling 

Services.

o Households that gained access to non-housing resources (e.g., social service programs, legal 

services, public benefits such as Social Security or Medicaid, etc.) after receiving Housing 

Counseling Services.

o Households that received a forward mortgage modification and improved their financial capacity 

after receiving Housing Counseling Services.

o Households that received a forward mortgage modification and remained current in their modified 

mortgage after receiving Housing Counseling Services.

.

PAHAF will also engage housing counseling agencies and other nonprofits in Program outreach to increase staffing 

resources required to execute a robust statewide mobile outreach campaign. Through mobile outreach, with the support 

of housing counseling agencies, the Program will increase its footprint across the Commonwealth by promoting 

PAHAF servicers and providing on-site application support.

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

homeowners’ efforts at engaging in loss mitigation.

The PAHAF program will provide training to housing counseling and legal services providers to ensure that they have

an understanding of PAHAF programming options, goals, and objectives. Such training will include requirements for 

reporting back to the PAHAF program. PHFA encourages the service providers to undertake loss mitigation support 

to homeowners as those entities determine to be in the best interest of their clients and according to those entities’ 

own internal governing procedures, regulations, and processes. Services provided by these organizations will be 

particularly important for PAHAF applicants whose delinquencies are over program maximum caps on assistance to 

work out strategies that can either fully resolve the applicant’s delinquency situation with their servicer or to work out

arrangements that will bring the necessary PAHAF assistance under program maximums.

• 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?

PHFA does recognize the importance of loss mitigation opportunities for homeowners. As such, a reference will be 

made in the application process making homeowners aware that there may be other loss mitigation options available 

through their servicers and that they are encouraged to explore such options. Additionally, the partnership with housing 

counseling and legal aid service providers will offer an opportunity for homeowners to explore these solutions.

The PAHAF program is not imposing any additional eligibility requirements related to a homeowner’s status with 

loss mitigation options. Doing so would be contrary to Treasury’s published HAF guidance by placing an additional 

eligibility burden on homeowners. Time is of the essence to avoid foreclosure and eviction. Based on the PAHAF 

team’s experience from the last housing crisis, homeowners that work directly with Mortgage Servicers are often 

confused about the requirements and the best path forward to save their home, so they often do nothing. By applying 

for HAF first, we can connect those homeowners with housing counselors and legal service providers, if HAF 

assistance alone is not that answer or it appears from the documentation they submitted, they need additional 

assistance.

• Please explain what steps, if any, your program will take to assist the homeowner in determiningwhether

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

The PAHAF program is designed to provide mortgage reinstatement, mortgage payment, utility, and associated 

homeownership cost assistance. As such the program will not result in a modification to a homeowner’s monthly 

payment. However, assistance is intended to provide homeowners with financial relief and time, including six months 

of forward paying assistance. Reinstating delinquent mortgages, paying off past due balances for homeownership 

costs, and providing forward paying mortgage assistance will offer homeowners the best chance to catch up on 

financial obligations and find new opportunities to stay current. PAHAF also refers homeowners to housing counseling 

to obtain assistance with adjusting budgets or obtaining other financial counseling assistance which may result in 

negotiations with servicers that could result in more sustainable payment terms. 
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• Are you anticipating increased winter home energy costs and their potential impact on the

homeowners that HAF will serve?

Yes. Utility assistance is available for qualified homeowners through the PAHAF program. Our needs assessment 

included the following information upon which the decision to include utility assistance in the program design was 

based. 

In February 2021 there were 814,508 ‘at risk’ accounts associated with $852,054,166 in outstanding 

debt reported by most of the commonwealth’s largest utility providers to the PA Utility Law Project 

. This represents roughly 16% of all PA households. While it is not possible to know which of these 

delinquent accounts are associated with renters and those associated with homeowners, a 

conservative estimate of 10% of the income eligible owner-occupied households in PA in need of 

utilities assistance would represent roughly 182,000 households. Additionally, a recent report from 

Philadelphia’s Community Legal Services and the PA Utility Law Project found that utility 

delinquencies are disproportionately concentrated among socially disadvantaged residents.5 [PAGE 

19]

Note that there are legal protections against utility terminations in Pennsylvania. This includes a prohibition of utility 

shutoff during the winter heating months, from December 1 to the end of March for very low-income families. This 

will afford PAHAF time to help homeowners catch up on arrearages without the threat of imminent utility 

disconnection as program launch will likely coincide with increased cold weather and utility need. 

Pennsylvania Utility Law Project and Community Legal Service-Energy Unit are two entities that will be funded by 

the PAHAF Legal Services Provider grant. 

Eligibility

• No Questions

Outreach

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

English proficiency.

The PAHAF program has a branded website which is available in both English and Spanish. The site has been 

translated into Spanish by a certified translation service. Additionally, all marketing materials will be made available 

in English and Spanish. As needed, the Program will work with local organizations that serve ethnically diverse groups 

to identify additional language needs, as necessary. 

The program administration vendor we have engaged will focus on outreach to homeowners with limited English 

proficiency and other social disadvantages identified in the PAHAF plan. This outreach could include, but is not 

limited to, outreach to faith-based community organizations, cultural groups, and cultural centers that cater to the 

needs of Pennsylvania citizens who require language assistance. 

The vendor will seek to employ bilingual staff members and may use certified translation services available through 

translation vendors via phone, web, or video service to ensure language assistance and equal access to the PAHAF 

program. In our Spanish translations, we ensure that materials are culturally appropriate for Spanish-speakers from 

Central America, South America, and the Caribbean. We will also ensure to provide outreach materials translated in 

other languages as the need arises using a reliable translation service. Our cloud-based and mobile application platform 

also offers translation of other languages.

Non-traditional and grassroots outreach may prove to be more effective in reaching some of the target populations, 

particularly methods based on guidance from local partners on what will work best in their communities. Additionally, 

printed materials have proven critical in past outreach endeavors. These will be used both at in-person events and in 

5 https://clsphila.org/wp-content/uploads/2021/03/CLS_UtilityReport_20200324.pdf
9

strategic mailings. Materials will be provided in both English and Spanish to ensure wider reach to socially 

disadvantaged individuals with information on how individuals who speak other languages can access personal 

assistance.

• Please explain how the program will provide culturally relevant marketing.

As noted above, the communications strategy focuses on the development and successful implementation of accessible 

and culturally relevant outreach and marketing materials that drive the call to action to apply for PAHAF assistance. 

We will produce and deliver materials and key messages through the most appropriate medium and in an easily 

digestible format.

• All Spanish materials will be run through a lens of Spanish-speakers from Central America, South 

America, and the Caribbean to ensure cultural relevance using in-house or contractor provided resources.

• The program will also work with local officials, community leaders, and partners in community-based 

and faith-based organizations to identify outreach materials and resources required to reach their 

constituents in a manner that is culturally sensitive and relevant. PAHAF will partner with community 

and ethnic organizations to leverage their existing outreach and communications infrastructure to greatly 

amplify exposure of the program and increase intake of potential applicants.

• The outreach team will seek out collaboration from partnering organizations that support amplification 

and awareness of program resources to non-English speaking communities. These not-for-profit 

organizations and community groups are trusted sources of information, understand and know the 

targeted audience and will be key to helping to meet the goal of reaching every eligible homeowner. In 

addition, we will work with community and ethnic publications for earned media and advertisements 

helping to reach eligible homeowners in the communities where they live and work.

Prioritization

• No Questions

Performance Goals

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

PHFA will report on the quarterly data elements and the one-time interim report data elements as defined Treasury 

guidance. Further, PHFA expects to produce periodic general administration reporting to state oversight authorities. 

PHFA will, at a minimum, provide a summary of these reports on the program website, after they have been submitted 

to the relevant oversight entity. Additionally, PHFA intends to create a weekly report that will provide key insight 

into total applications, approvals, denials, total funding approved, total distributions, and other metrics that 

demonstrate program progress. These reports will be easily accessible at the following link: https://pahaf.org/policiesand-reporting/. Additional program progress reports may be published as need arises.

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

The three metrics that will serve as the best indicators of success include:

1. Number of homeowners and dollars of financial assistance provided through the PAHAF Program.

2. Number of socially disadvantaged homeowners and dollars of financial assistance provided.

3. Meeting and exceeding the minimum 60% Treasury requirement for assistance provided to applicants at or 

below 100% of the AMI.
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Though these three metrics will demonstrate success factors for the program, PHFA also believes that the following 

statistics will be informative:

• Average assistance requested versus disbursed.

• Percent or share of homeowners that are Socially Disadvantaged Individuals and below 100% AMI.

• Data broken out by ZIP Code/County/Census Tract.

• Outcomes identified in this document specific to housing counseling and legal service providers

• Share of beneficiaries who avoid involuntary displacement within 12 months of receiving benefit (Program 

staff members may need to extrapolate data or define proxies to count homeowners in this category.) 

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

The application has been designed to collect this information and can be reported against in a disaggregated manner.

• 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.

PHFA is coordinating services with housing counseling agencies and legal service providers. As part of this 

coordination, PHFA and its vendor are establishing a reporting mechanism to track services provided by these entities 

for homeowners who are applicants to the PAHAF program. Though we anticipate being able to track the outcomes 

of these cases and reporting these statistics, However, to the extent that such data may be captured by partnering 

agencies and is made available to PHFA, PHFA will report it.

As stated in response to previous question, PHFA has established outcome-based reporting for the housing counseling 

and legal services providers who will be partnering with the program. Examples of outcomes that PAHAF expects to 

be able to report against include:

• Legal Service Providers (LSP)

o Non-HAF Assistance Obtained 

o Obtained forbearance, loan modification, or other loss mitigation

o Debt/fees avoided

o Bankruptcy discharge obtained

o Client became record owner of property 

o Assistance unable to be obtained

o Assistance with property taxes obtained

o Assistance with utilities obtained

o Assistance with insurance obtained

• Housing Counseling

o Households that obtained forbearance or other loss mitigation after receiving Housing Counseling 

Services.

o Households for whom counselor provided assistance with HAF Application 

o Households for whom counselor developed mortgage payment plan.

o Assistance unable to be obtained

o Households that prevented or resolved a mortgage default after receiving Housing Counseling 

Services.

o Households that prevented or resolved a reverse mortgage default after receiving Housing 

Counseling Services.

o Households for whom counselor developed a sustainable household budget through the provision 

of financial management and/or budget services.
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o Households for whom counselor developed a budget customized to a client’s current situation.

o Households that gained access to resources to help them improve their housing situation (e.g. utility 

assistance, taxes, HOA/condominium fees, or insurance etc.) after receiving Housing Counseling 

Services.

o Households that gained access to non-housing resources (e.g., social service programs, legal 

services, public benefits such as Social Security or Medicaid, etc.) after receiving Housing 

Counseling Services.

o Households that received a forward mortgage modification and improved their financial capacity 

after receiving Housing Counseling Services.

o Households that received a forward mortgage modification and remained current in their modified 

mortgage after receiving Housing Counseling Services.

Readiness

• Please provide the most recent available information about your program's readiness, includingstaffing,

contractors, etc.

The PHFA internal management team has been working on the design and implementation of the PAHAF program 

since HAF funding was first announced. This team has remained stable with little to no turnover. This team has also 

successfully launched and run the PAHAF Pilot Program.

PHFA has augmented this team by contracting with a vendor for long-term operational support and implementation. 

That contractor has been supporting the agency since September 2021. PHFA’s implementation contractor is 

providing PHFA with program support services that include:

1. application design and online portal creation, 

2. outreach/marketing strategy support, 

3. call center standup, operations, and management, 

4. case management services including application intake and eligibility review, 

5. coordination of CDF data transfer and other payee notifications,

6. payment of benefits on behalf of eligible homeowners to qualified payees,

7. quality control,

8. file closeout, and 

9. reporting.

PHFA has completed PAHAF branding and design requirements. PHFA and the implementation contractor have 

developed and continue to develop materials for the PAHAF website and a marketing plan with collateral material 

design to ensure that we can begin marketing the full program as soon as it launches. 

The program first established policies, procedures, and workflows for pilot program operations. These have been 

updated and maintained over time as lessons have been learned and new processes are developed. Task level activities 

necessary to execute outreach, intake, eligibility, quality control, and payment have been developed. The program has 

standard operating procedures for task level activities and is continuing to develop new standard operating procedures 

as new tasks are identified. Staff training on program rules, process workflows, systems, and tools is conducted at 

staff onboarding and on an ongoing basis.

Together, PHFA and the implementation contractor have stood up and activated a call center, case management 

services, an online application portal, and eligibility review workflows. The Pilot Program implementation was 

transferred to the PHFA implementation vendor December 1, 2021. Together we continue to build out new processes, 

including automation of application activities, streamlining application activities and requirements, and development 

of the CDF process. This has included staffing up and training as applicant influx is anticipated to increase.
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PHFA is working toward full program launch and anticipates that the full program will be substantially similar to the 

PAHAF Pilot. The biggest difference between the two will be an expansion of program options available under the 

full program. The team continues building out the system, policy, and procedure requirements that will apply beyond 

those of the pilot program.

PHFA is identifying process bottlenecks and policy gaps, formulating resolution, and implementing changes to address 

them. These program improvements are intended to create a system ready for full operation when Treasury approves 

the HAF Plan. 

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

following approval?

Currently, there are more than 4,000 homeowners who have registered through the PAHAF Get Notified list, who 

have demonstrated interest in seeking PAHAF assistance. The Program will use this list as an outreach opportunity 

and invite these homeowners to apply through expansion of the PAHAF Pilot Program.

PHFA believes that the PAHAF program is ready for launch within 30-45 days of receipt of Treasury approval of the 

PAHAF Plan, but no later than February 1, 2022. The necessary infrastructure for full program launch is in place, 

working drafts of policies and procedures have been developed, systems are functional to handle increased volume of 

applications, plans have been activated to ensure appropriate staffing levels, and controls are in place to support antifraud, waste and abuse protocols. 

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

jurisdiction’s full allocation and the status of any pilot assistance already offered or made available to

homeowners.

PHFA has spent $826,768 on start-up activities of the total 10% allocation received. This includes applicant assistance 

disbursed as well as administrative expenses, outreach and marketing expenses, as well as bilingual communication 

expenses to support plan development, publication, and program planning. 

The statistics on the pilot program are updated below:

Number of households that have applied for assistance: 385

Number of households that have received funding: 267

Amount of funding disbursed: $2,800,824.26

There are an additional 118 applications undergoing the eligibility review process currently. The estimated need 

associated with the pending applications is $2,551,387.00.

Budget

• No Questions