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Homeowner Assistance Fund:

Guidance on Participant Compliance and Reporting 

Responsibilities

March 30, 2022

For More Information: Please visit www.treasury.gov/HAF

For Media Inquiries: Please contact the U.S. Treasury Press Office at (202) 622-2960

For General Inquiries: Please email HAF@treasury.gov for additional information

U.S. DEPARTMENT OF THE TREASURY
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Homeowner Assistance Fund:

Guidance on Participant Compliance and Reporting Responsibilities

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Table of Contents

Definitions............................................................................................................................ 2

Part 1: General Guidance ....................................................................................................... 4

Guiding Principles ............................................................................................................... 4

Eligible Participants ............................................................................................................. 5

Qualified Expenses ............................................................................................................. 5

Reimbursable Expenses Incurred Prior to HAF Award ....................................................... 6

Reporting............................................................................................................................. 6

Uniform Administrative Requirements................................................................................. 7

Other Compliance Obligations .......................................................................................... 10

Part 2: Reporting Requirements and Deadlines ................................................................... 11

Quarterly Report................................................................................................................ 12

Executive Summary....................................................................................................... 12

Quarterly Reporting ....................................................................................................... 12

Annual Performance Report.............................................................................................. 16

Executive Summary....................................................................................................... 16

Annual Performance Reporting ..................................................................................... 16

Appendix 1 – Race, Ethnicity and Gender Categories.......................................................... 19

Appendix 2 – Targeting Categories ...................................................................................... 20

Appendix 3 – Program Design Element Categories ............................................................. 22
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Homeowner Assistance Fund

Guidance on Recipient Compliance and Reporting 

Responsibilities

On March 11, 2021, the American Rescue Plan Act was signed into law, and established the 

Homeowner Assistance Fund (“HAF”) program. This program provides funding to eligible 

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

foreclosures, loss of utilities or home energy services, and displacements of homeowners 

experiencing financial hardship after January 21, 2020, through qualified expenses related to 

mortgages and housing. 

This guidance provides additional detail and clarification for each participant’s compliance and 

reporting responsibilities under the HAF program, and should be read in concert with the HAF 

Financial Assistance Agreement, the authorizing statute, the Homeowner Assistance Fund 

Guidance (the “HAF Guidance”) and other regulatory and statutory requirements, including 

regulatory requirements under the Uniform Guidance (2 CRF Part 200). Please see the 

Assistance Listing in SAM.gov under assistance listing number (formerly known as CFDA 

number), 21.026 for more information. 

Please Note: This guidance document applies to the HAF program only. This guidance 

contains two parts: Part 1 addresses general guidance and Part 2 addresses reporting 

requirements and deadlines.

Definitions

Award Date means the date the HAF participant signed the HAF Financial Assistance 

Agreement.

Delinquency(ies) means an obligation on which a Homeowner was past due on any housing 

related HAF qualified expense.1

Eligible Entity2 means (1) a State, (2) the Department of Hawaiian Home Lands, (3) each 

Indian Tribe (or, if applicable, the tribally designated housing entity of an Indian Tribe) that 

was eligible for a grant under Title I of the Native American Housing Assistance and Self 

Determination Act of 1996 (25 U.S.C. 4111 et seq.) for fiscal year 2020, and (4) any Indian

Tribe that opted out of receiving a grant allocation under the Native American Housing Block

Grants program formula in fiscal year 2020.

Expenditure/Expended means any HAF assistance that has been spent by a HAF participant 

and/or Subrecipient. Please note, cumulative Expenditures cannot exceed cumulative 

Obligations.

Financial hardship3 means a material reduction in income or material increase in living 

expenses associated with the coronavirus pandemic that has created or increased a risk of 

1 Reference definition published in HAF Guidance published on August 2, 2021 (Updated November 

12, 2021). Refer to the qualified expenses noted in the HAF Guidance. 

2 Reference section published in HAF Guidance published on August 2, 2021 (Updated November 12, 

2021)

3 Reference definition published in HAF Guidance published on August 2, 2021 (Updated November 

12, 2021)
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mortgage delinquency, mortgage default, foreclosure, loss of utilities or home energy services, 

or displacement for a homeowner.

HAF participant4 means an Eligible entity that receives funds from the HAF.

HAF assistance means any assistance provided by the HAF program, weather through funds 

received by the HAF program for qualified expenses or through services made available by 

the HAF program.

Monetary HAF Assistance means HAF assistance in the form of money that was 

provided to Homeowners, financial institutions, utility providers, and taxing authorities 

under a HAF Program. 

Non-monetary HAF Assistance means HAF assistance in any form other than money 

that was provided to Homeowners under a HAF Program (i.e., housing counseling).

HAF application means an application submitted by the unique Homeowner to the HAF 

participant or Subrecipient used to determine eligibility to receive HAF assistance for qualified 

expenses.

Homeowner means an individual who applied and/or receives funds from the HAF participant 

or Subrecipient to pay for a singular qualified expense (i.e., if a Homeowner receives HAF 

assistance for more than one qualified expense category, they are counted for more than one 

qualified expense category).

In some places, the Interim Guidance requires that you provide the number of unique

Homeowners. Unique Homeowners are only counted one time even if they applied and 

or/received funding for more than one qualified expense category.

Maximum conforming loan limit5 means the applicable limitation governing the maximum 

original principal obligation of a mortgage secured by a single-family residence, a mortgage 

secured by a two-family residence, a mortgage secured by a three-family residence, or a 

mortgage secured by a four-family residence, as determined and adjusted annually under 

section 302(b)(2) of the Federal National Mortgage Association Charter Act (12 U.S.C. 

1717(b)(2)) and section 305(a)(2) of the Federal Home Loan Mortgage Corporation Act (12 

U.S.C. 1454(a)(2)).

Obligation/Obligated means an order placed for property and services, contracts and 

subawards made, and similar transactions that require payment (see 2 CFR § 200.1.). 

Obligated funds include funds that have been Expended. 

• Examples of obligated funds include: HAF funds that have been committed, pledged, 

or otherwise promised, in writing, to a specific individual or entity as part of a HAF 

program; HAF funds that have been set aside to cover obligations arising from loan 

guarantees; HAF funds that have been committed, pledged, or otherwise promised, in 

writing, as part of a transaction; and HAF funds that have been committed, pledged, 

or promised, in writing, for allowable administrative expenses (e.g., an executed 

contract for services).

4 Reference definition published in HAF Guidance published on August 2, 2021 (Updated November 

12, 2021)

5 Reference definition published in HAF Guidance published on August 2, 2021 (Updated November 

12, 2021)
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Program Design Elements are the following: Mortgage Payment Assistance, Financial 

Assistance, Mortgage Principal Reduction, Facilitating Interest Rate, Payment Assistance 

Utilities, Payment Assistance Internet, Payment Assistance Insurance, Payment Assistance 

Fees, Payment Assistance Loans, Payment Assistance Taxes, Measures Preventing 

Displacement, Counseling or Education and Legal Services which align to eight of the qualified 

expenses (excludes administrative expenses).

Socially Disadvantaged Individual6 are those whose ability to purchase or own a home has 

been impaired due to diminished access to credit on reasonable terms as compared to others 

in comparable economic circumstances, based on disparities in homeownership rates in the 

HAF participant’s jurisdiction as documented by the U.S. Census. The impairment must stem 

from circumstances beyond their control. Indicators of impairment under this definition may 

include being a (1) member of a group that has been subjected to racial or ethnic prejudice or 

cultural bias within American society, (2) resident of a majority-minority Census tract; (3) 

individual with limited English proficiency; (4) resident of a U.S. territory, Indian reservation, or 

Hawaiian Home Lands, or (5) individual who lives in a persistent-poverty county, meaning any 

county that has had 20% or more of its population living in poverty over the past 30 years as 

measured by the three most recent decennial censuses. In addition, an individual may be 

determined to be a socially disadvantaged individual in accordance with a process developed 

by a HAF participant for determining whether a homeowner is a socially disadvantaged 

individual in accordance with applicable law, which may reasonably rely on self-attestations.

State means any state of the United States, the District of Columbia, the Commonwealth 

of Puerto Rico, Guam, American Samoa, the United States Virgin Islands, and the 

Commonwealth of the Northern Mariana Islands. 

Subrecipient as defined in the Uniform Guidance (see 2 CFR § 200.1).

Part 1: General Guidance

This section provides an orientation for HAF participants regarding their compliance 

responsibilities and Treasury’s expectations and recommended best practices where 

appropriate under the HAF program.

HAF participants are the eligible entities identified in Title III, Subtitle B, Section 3206 of 

American Rescue Plan Act of 2021 (the “HAF statute”) and the HAF Guidance that receive a 

HAF award. Subrecipients under the HAF program (“Subrecipients”) are entities that receive 

a subaward from a HAF participant to carry out the purposes of the HAF award on behalf of 

the HAF participant.

HAF participants are accountable to Treasury for oversight of their Subrecipients, including 

ensuring the Subrecipients comply with the HAF statute, HAF Financial Assistance 

Agreement, HAF Guidance, applicable, federal statutes, regulations, and reporting 

requirements. 

Guiding Principles

There are several guiding principles for developing effective compliance regimes under HAF:

• HAF participants are responsible for ensuring HAF award funds are used for approved 

6 Reference definition published in HAF Guidance published on August 2, 2021 (Updated November 

12, 2021)
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purposes, and developing an internal control program designed to minimize the risk of 

fraud, waste and abuse associated with their HAF award; 

• Many HAF-funded programs respond to the COVID-19 public health emergency and meet 

urgent community needs. Swift and effective implementation is vital, and Participants must 

balance facilitating program access and maintaining a robust documentation and 

compliance regime;

• HAF-funded programs should advance shared interests and promote equitable delivery 

of government benefits and opportunities to underserved communities, as outlined in 

Executive Order 13985, On Advancing Racial Equity and Support for Underserved 

Communities Through the Federal Government; and

• Transparency and public accountability for HAF awards and use of such funds are critical 

to upholding program integrity and trust in all levels of government, and HAF awards

should be managed consistent with Administration guidance per Memorandum M-21-20

and Memorandum M-20-21.

Eligible Participants

The HAF Statute and HAF Guidance identifies Department of Hawaiian Home Lands, States

(defined to include the District of Columbia and territories), and Tribes or their tribally 

designated housing entity (TDHE) , as the entities eligible receive HAF funds.

• Eligible states (“States”) are any state of the United States, the District of Columbia, 

the Commonwealth of Puerto Rico, Guam, American Samoa, the United States Virgin 

Islands, and the Commonwealth of the Northern Mariana Islands.7

• The Department of Hawaiian Home Lands.8

• Eligible Tribal Governments (“Tribal Governments”) are Indian Tribes (or, if applicable, 

the tribally designated housing entity of an Indian Tribe) that were eligible for a grant 

under Title I of the Native American Housing Assistance and Self-Determination Act of 

1996 (25 U.S.C. 4111 et seq.) for fiscal year 2020 or Indian Tribes that opted out of 

receiving a grant allocation under the Native American Housing Block Grants 

program formula in fiscal year 2020.9

HAF participants may award funds to Subrecipients, such as other levels or units of 

government (e.g., a municipality), non-profits, or private entities.

Qualified Expenses

HAF participants may use their HAF award funds only for the following types of qualified 

expenses that are for the purpose of preventing homeowner mortgage delinquencies, 

homeowner mortgage defaults, homeowner mortgage foreclosures, homeowner loss of 

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

hardship:

1. mortgage payment assistance;

2. 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;

3. mortgage principal reduction, including with respect to a second mortgage provided 

by a nonprofit or government entity;

4. facilitating mortgage interest rate reductions;

5. payment assistance for:

a. homeowner’s utilities, including electric, gas, home energy (including firewood 

and home heating oil), water, and wastewater;

7 Title III, Subtitle B, Section 3206(b)(7) of the American Rescue Plan Act of 2021. 

8 HAF Guidance published on August 2, 2021 (Updated November 12, 2021).

9 HAF Guidance published on August 2, 2021 (Updated November 12, 2021).
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b. homeowner’s internet service, including broadband internet access service, as 

defined in 47 CFR 8.1(b) (or any successor regulation);

c. homeowner’s insurance, flood insurance, and mortgage insurance;

d. homeowner’s association fees or liens, condominium association fees, or 

common charges, and similar costs payable under a unit occupancy agreement by 

a resident member/shareholder in a cooperative housing development; and

e. down payment assistance loans provided by nonprofit or government entities;

6. payment assistance for delinquent property taxes to prevent homeowner tax 

foreclosures;

7. measures to prevent homeowner displacement, such as home repairs to maintain 

the habitability of a home, including the reasonable addition of habitable space to 

alleviate overcrowding, or assistance to enable households to receive clear title to their 

properties;

8. counseling or educational efforts by housing counseling agencies approved by HUD 

or a tribal government, or legal services, targeted to households eligible to be served 

with funding from the HAF related to foreclosure prevention or displacement, in an 

aggregate amount up to 5% of the funding from the HAF received by the HAF 

participant;

9. reimbursement of funds expended by a state, local government, or entity described 

in clause (3) or (4) of the definition above of “eligible entity” during the period beginning 

on January 21, 2020, and ending on the date that the first funds are disbursed by the 

HAF participant under the HAF, for a qualified expense (other than any qualified 

expense paid directly or indirectly by another federal funding source, or any qualified 

expenses described in clauses (6), (7), (8), or (10) of this definition); and

10. planning, community engagement, needs assessment, and administrative 

expenses related to the HAF participant’s disbursement of HAF funds for qualified 

expenses, in an aggregate amount not to exceed 15% of the funding from the HAF 

received by the HAF participant.

Arrearages of qualified expenses are eligible for purposes of the HAF program regardless of 

the date they were incurred, including if they arose before January 2020. Funding from the 

HAF program may not be used for any use other than those provided for in this section. To 

the extent that HAF participants use their HAF award funds to supplement other lossmitigation efforts, Treasury encourages participants to avoid using HAF award funds in a 

manner that replaces other loss-mitigation resources that would otherwise be available. 

Reimbursable Expenses Incurred Prior to HAF Award

HAF participants may use their HAF award funds to cover qualified expenses that they

incurred during the period that began on January 21, 2020 (or the date of initial qualifying 

administrative and housing activity). See number #9 in Qualified Expenses above for terms 

regarding reimbursement of funds during the period beginning on January 21, 2020, and 

ending on the date that the first funds are disbursed by the HAF participant under the HAF.

Reporting 

HAF participants will be required to submit quarterly reports until September 30, 2026 and 

final reports are due no later than 120 calendar days after the end of the period of performance 

on September 30, 2026.

The reports will include financial data, types of programs funded, program design element 

information, and other information regarding a HAF participants’ utilization of the award funds. 

Certain reporting may continue on an annual basis for four years, until August 2027, to ensure 

that programs funded by the HAF program maintain operations. HAF participants will also be 
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required to submit an Annual Performance Report to Treasury regarding the impact of the

HAF award funds and overall HAF program. 

Refer to Part 2 for further details. 

Uniform Administrative Requirements

The HAF award funds are generally subject to the requirements set forth in the Uniform 

Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 

CFR Part 200 (the “Uniform Guidance”). In all instances, a HAF participant should review the 

Uniform Guidance requirements applicable to their organization’s use of HAF award funds, 

and HAF-funded programs. HAF participants should consider how and whether certain 

aspects of the Uniform Guidance apply. 

1. Allowable Activities. Each HAF participant should review program requirements and the

HAF participant’s Financial Assistance Agreement, HAF statute, and HAF guidance to 

determine and record eligible uses of HAF award funds. Per 2 CFR 200.303, a HAF 

participant must develop and implement effective internal controls to ensure that funding 

decisions under the HAF award constitute eligible uses of funds, and document 

determinations.

2. Allowable Costs/Cost Principles. As outlined in the Uniform Guidance at 2 CFR Part 

200, Subpart E regarding Cost Principles, allowable costs are based on the premise that 

a HAF participant is responsible for the effective administration of Federal awards, 

application of sound management practices, and administration of Federal funds in a 

manner consistent with the program objectives and terms and conditions of the award. 

HAF participants must implement robust internal controls and effective monitoring to 

ensure compliance with the Cost Principles, which are important for building trust and 

accountability. 

HAF award funds may be, but are not required to be, used along with other funding sources 

for a given project. Note that HAF award funds may not be used for a non-Federal cost 

share or match where prohibited by other Federal programs, e.g., funds may not be used 

Assistance Listing

The Assistance Listing for the Homeowners Assistance Fund was published August 12, 

2021 on SAM.gov under Assistance Listing Number (“ALN”), formerly known as CFDA 

Number, 21.026.

The assistance listing includes helpful information including program purpose, statutory 

authority, eligibility requirements, and compliance requirements for Participants. The ALN 

is the unique 5-digit number assigned to identify a federal assistance listing and can be 

used to search for federal assistance program information, including funding 

opportunities, spending on USASpending.gov, or audit results through the Federal Audit 

Clearinghouse. 

Participants must use ALN 21.026 for all financial accounting, subawards, and 

associated program reporting requirements for the HAF awards.
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for the State share for Medicaid.10

a. Administrative costs: Planning, community engagement, needs assessment, and 

administrative expenses related to the HAF participant’s disbursement of HAF funds 

for qualified expenses, in an aggregate amount, must not exceed 15% of the funding 

from the HAF received by the HAF participant. 

Consistent with 2 C.F.R. § 200.414(f), eligible applicants that do not have a current 

negotiated indirect cost rate may elect to charge indirect costs to an award pursuant 

to a de minimis rate of ten percent of the modified total direct costs (MTDC) for 

program administration.

As described in 2 C.F.R. § 200.403 (d), costs must be accorded consistent treatment. 

A cost may not be assigned to a Federal award as a direct cost if any other cost 

incurred for the same purpose in like circumstances has been allocated to the 

Federal award as an indirect cost.

3. Eligibility. Under this program, HAF participants are responsible for ensuring funds are 

used for eligible purposes. Generally, HAF participants must develop and implement 

policies and procedures, and record retention, to determine and monitor implementation 

of criteria for determining the eligibility of beneficiaries and / or Subrecipients. HAF 

participants, and if applicable, the Subrecipient(s) administering a program on behalf of 

the HAF participant, will need to maintain procedures for obtaining information evidencing 

a given beneficiary, Subrecipient, or contractor’s eligibility including a valid SAM.gov 

registration. Implementing risk-based due diligence for eligibility determinations is a best 

practice to augment your organization’s existing controls.

4. Equipment and Real Property. Any purchase of equipment or real property with HAF

award funds must be consistent with the Uniform Guidance at 2 CFR Part 200, Subpart D. 

Equipment and real property improved under this program must be used for the originally 

authorized purpose. Consistent with 2 CFR 200.311 and 2 CFR 200.313, any equipment

acquired or real property improved with HAF funds shall vest in the non-Federal entity.

Any acquisition and maintenance of equipment or improvement to real property must also 

comply with relevant laws and regulations.

5. Matching, Level of Effort, Earmarking. There are no matching, level of effort, or 

earmarking compliance responsibilities associated with the HAF award. HAF award funds 

may only be used for non-Federal match in other programs where costs are eligible under 

both HAF and the other program and use of such funds is not prohibited by the other 

program.

6. Period of Performance. The period of performance under the HAF award begins on the 

date the Financial Assistance Agreement was executed and ends on September 30, 2026. 

Any funds not used during this period must be returned to Treasury as part of the award 

closeout process pursuant to 2 CFR 200.344(d).

7. Procurement, Suspension & Debarment. HAF participants are responsible for ensuring 

that any procurement using HAF award funds must comply with the procurement 

10 See 42 CFR 433.51 and 45 CFR 75.306.
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standards set forth in the Uniform Guidance at 2 CFR 200.317 through 2 CFR 200.327, as 

applicable. HAF participants must have and use documented procurement procedures 

consistent with the standards outlined in 2 CFR 200.317 through 2 CFR 200.320, as 

applicable. The Uniform Guidance requires an infrastructure for competitive bidding and 

contractor oversight, including maintaining written standards of conduct and prohibitions 

entering into contracts or subawards with suspended or debarred parties.

8. Program Income. 

Funding from the HAF may not be used for any use other than qualified expenses and 

reimbursements. HAF participants may use program income earned during the period of 

performance as a result of implementing the objectives of the HAF award for eligible 

purposes outlined in this guidance. “Program income” is defined in 2 C.F.R. § 200.1 as 

gross income earned by a non-federal entity that is generated directly by a supported 

activity or earned as a result of the federal award during the period of performance except 

as provided by 2 C.F.R. § 200.307(f). Program income includes income from fees for 

services performed, the use or rental of real or personal property acquired under federal 

awards, and principal and interest on loans made with federal award funds. To the extent 

that HAF participants use HAF funds to supplement other loss-mitigation efforts, Treasury 

encourages participants to avoid using HAF funds in a manner that replaces other lossmitigation resources that would otherwise be available. 

9. Reporting. All HAF participants of federal funds must complete financial, performance, 

and compliance reporting as required and outlined in Part 2 of this guidance. Expenditures 

may be reported on a cash or accrual basis, as long as the methodology is disclosed and 

consistently applied. Reporting must be consistent with the definition of expenditures 

pursuant to 2 CFR 200.1. HAF participants should appropriately maintain accounting 

records for compiling and reporting accurate, compliant financial data, in accordance with 

appropriate accounting standards and principles.

In addition, where appropriate, HAF participants must establish controls to ensure 

completion and timely submission of all mandatory performance and/or compliance 

reporting. For a full overview of HAF participant reporting responsibilities see Part 2 of this 

guidance.

10. Subrecipient Monitoring. HAF participants that are pass-through entities as defined 

under 2 CFR 200.1 are required to manage and monitor their Subrecipients to ensure 

compliance with requirements of the HAF award pursuant to 2 CFR 200.332 regarding 

requirements for pass-through entities. 

First, HAF participants must clearly identify to the Subrecipient: (1) that the award is a 

subaward of HAF award funds; (2) any and all compliance requirements for use of HAF

award funds; and (3) any and all reporting requirements for expenditures of HAF award 

funds. 

Next, HAF participants will need to evaluate each Subrecipient’s risk of noncompliance 

based on a set of common factors. These risk assessments may include factors such as 

prior experience in managing Federal funds, previous audits, personnel, and policies or 

procedures for award execution and oversight. Ongoing monitoring of any given 

Subrecipient should reflect its assessed risk and include monitoring, identification of 

deficiencies, and follow-up to ensure appropriate remediation.
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Accordingly, HAF participants should develop written policies and procedures for 

Subrecipient monitoring and risk assessment and maintain records of all award 

agreements identifying or otherwise documenting Subrecipients’ compliance obligations.

HAF participants should also note that Subrecipients do not include individuals and 

organizations that received HAF funds as end users to prevent homeowner mortgage 

delinquencies, defaults, foreclosures, loss of utilities or home energy services, and 

displacements. Such individuals and organizations are beneficiaries and not subject to 

audit pursuant to the Single Audit Act and 2 C.F.R. Part 200, Subpart F.

Other Compliance Obligations

HAF participants should ensure they remain in compliance with all Financial Assistance 

Agreement Terms and Conditions. These obligations include the following items in addition to 

those described above: 

1. SAM.gov Requirements. All eligible HAF participants are required to have an active 

registration with the System for Award Management (SAM) (https://www.sam.gov)

pursuant to 2 CFR Part 25.

2. FSRS.gov Reporting Requirements. All HAF participants are required to report 

subaward and executive compensation data pursuant to 2 CFR Part 170, Appendix A 

award term so that it may be made available to the public via www.USASpending.gov. HA 

participants will use the FSRS.gov reporting tool to report on subawards obligated that are 

in the amount of $30,000 or more. HAF participants must report their executive 

compensation as well as their contract data in SAM.gov.

3. Recordkeeping Requirements. Generally, a HAF participant must maintain records and 

financial documents for five years after all award funds have been expended or returned

to Treasury, as outlined in paragraph 5 of the Financial Assistance Agreement. Treasury 

may request transfer of records of long-term value at the end of such period. Wherever 

practicable, such records should be collected, transmitted, and stored in open and 

machine-readable formats. 

4. Single Audit Requirements. HAF participants and Subrecipients that expend more than 

$750,000 in Federal awards during their fiscal year will be subject to an audit under the 

Single Audit Act and its implementing regulation at 2 CFR Part 200, Subpart F regarding 

audit requirements.11 HAF participants and Subrecipients may also refer to the Office of 

Management and Budget (OMB) Compliance Supplements for audits of federal funds and 

related guidance and the Federal Audit Clearinghouse to see examples and single audit 

submissions.

Non-Federal entities that expend less than $750,000 a year in Federal awards are

exempt from an audit under the Single Audit Act and 2 CFR Part 200, Subpart F for that 

fiscal year, except as noted in 2 CFR 200.503. 

5. Civil Rights Compliance. HAF participants of Federal financial assistance from the 

Treasury are required to meet legal requirements relating to nondiscrimination and 

nondiscriminatory use of Federal funds. Those requirements include ensuring that entities 

receiving Federal financial assistance from the Treasury do not deny benefits or services, 

or otherwise discriminate on the basis of race, color, national origin (including limited 

11 For-profit entities that receive HAF subawards are not subject to Single Audit requirements. 

However, they are subject to other audits as deemed necessary by authorized governmental entities, 

including Treasury, the GAO, the PRAC and the Treasury’s OIG. 
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English proficiency), disability, age, sex (including sexual orientation and gender identity), 

religion, or familial status, in accordance with the following authorities: Title VI of the Civil 

Rights Act of 1964 (Title VI) Public Law 88-352, 42 U.S.C. 2000d-1 et seq., and the 

Department's implementing regulations, 31 CFR part 22; Section 504 of the Rehabilitation 

Act of 1973 (Section 504), Public Law 93-112, as amended by Public Law 93-516, 29 

U.S.C. 794; Title IX of the Education Amendments of 1972 (Title IX), 20 U.S.C. 1681 et 

seq., and the Department's implementing regulations, 31 CFR part 28; Age Discrimination 

Act of 1975, Public Law 94-135, 42 U.S.C. 6101 et seq., and the Department implementing 

regulations at 31 CFR part 23; and the Fair Housing Act, Title VIII of the Civil Rights Act, 

42 U.S.C. 3601 et seq. In order to carry out its enforcement responsibilities under Title VI 

of the Civil Rights Act, Treasury will collect and review information from HAF participants

to ascertain their compliance with the applicable requirements before and after providing 

financial assistance. Treasury’s implementing regulations, 31 CFR part 22, and the 

Department of Justice (DOJ) regulations, Coordination of Non-discrimination in Federally 

Assisted Programs, 28 CFR part 42, provide for the collection of data and information from 

Participants (see 28 CFR 42.406). Treasury may request that non-tribal HAF participants

submit data for post-award compliance reviews, including information such as a narrative 

describing their Title VI compliance status.

Part 2: Reporting Requirements and Deadlines 

There are two types of reporting requirements for the HAF program. 

• Quarterly Report: Report on programs funded, expenditures, program status, and other 

information. 

.

• Annual Performance Report: Report updating the HAF participants Grantee Plan on 

programs undertaken with program funding and how the HAF participant plans to ensure 

program outcomes are achieved in an effective, efficient, and equitable manner. This 

report will include status updates on program goals identified by the HAF participant and 

additional mandatory indicators identified by Treasury. 

The Annual Performance Report will be posted on the website of the HAF participant as 

well as provided to Treasury.

Table 1: Reporting requirements by HAF participant type

Recipient Quarterly Report Annual Performance Report

States 

By May 16, 2022, and then 

45 days after the end of 

each quarter thereafter.

By August 15, 2022, and 

annually thereafter by midTribal Governments with August.

Allocation > $5M

Tribal Governments with 

Allocation < $5M & Department of 

Hawaiian Home Lands

By August 15, 2022, and 

annually thereafter by midAugust.

The remainder of this document describes these reporting requirements. A user guide will be 

provided with additional information on how and where to submit required reports.
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Quarterly Report

Executive Summary

HAF participants are required to quarterly reports that include data regarding programs, 

expenditures, demographic distribution, civil rights compliance, equity indicators, community 

engagement efforts, and programmatic data. To provide public transparency on whether 

programs are using practices that promote on-time and on-budget delivery, Treasury will seek 

information from HAF participants on their workforce plans and practices related to HAF

programs. The requirements that are not applicable to Tribal Governments and the 

Department of Hawaiian Home Lands are noted in subsequent sections.

Quarterly Reporting

The following HAF participants are required to submit quarterly reports: 

• States

• The Department of Hawaiian Home Lands12

• Tribal Governments13

The initial Quarterly Report will cover the Award Date to March 31, 2022 period and must be 

submitted to Treasury by May 16, 2022. The subsequent Quarterly Reports will cover one 

calendar quarter and must be submitted to Treasury within 45 calendar days after the end of 

each calendar quarter. Quarterly Reports are due concurrently with applicable Annual 

Performance Reports. The table below summarizes the Quarterly Report timelines:

Report Year Quarter Period Covered Due Date

1 2022 1 Award Date – March 31 Monday, May 16, 2022

2 2022 2 Award Date – June 30 Monday, August 15, 2022

3 2022 3 Award Date – September 30 Monday, November 15, 2022

4 2022 4 Award Date – December 31 Wednesday, February 15, 2023

5 2023 1 Award Date – March 31 Monday, May 15, 2023

6 2023 2 Award Date – June 30 Tuesday, August 15, 2023

7 2023 3 Award Date – September 30 Wednesday, November 15, 2023

8 2023 4 Award Date – December 31 Thursday, February 15, 2024

9 2024 1 Award Date – March 31 Wednesday, May 15, 2024

10 2024 2 Award Date – June 30 Thursday, August 15, 2024

11 2024 3 Award Date – September 30 Friday, November 15, 2024

12 2024 4 Award Date – December 31 Monday, February 17, 2025

13 2025 1 Award Date – March 31 Thursday, May 15, 2025

14 2025 2 Award Date – June 30 Friday, August 15, 2025

15 2025 3 Award Date – September 30 Monday, November 17, 2025

16 2025 4 Award Date – December 31 Monday, February 16, 2026

17 2026 1 Award Date – March 31 Friday, May 15, 2026

18 2026 2 Award Date – June 30 Monday, August 17, 2026

19 2026 3 Award Date – September 30 Monday, November 16, 2026

12 Please note that the Department of Hawaiian Home Lands will not be required to submit certain 

reporting requirements in their templates, which are noted in the footnotes of this section.

13 Please note that Tribal Governments will not be required to submit certain reporting requirements in 

their templates, which are noted in the footnotes of this section. Tribal Governments with allocations 

greater than $5 million will need to submit quarterly reports starting in Calendar Quarter 1 of 2022 with 

submissions due by May 16, 2022. Tribal Governments with allocations less than $5 million will 

submit annual reports (same content as quarterly reports for Tribal Governments with allocations 

greater than $5 million) starting in in Calendar Quarter 2 of 2022 with submissions due by August 15, 

2022.
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Report Year Quarter Period Covered Due Date

20 2027 Final 

Report

Award Date – September 30 Wednesday, January 28, 2027

Programmatic Information Requirements

The following programmatic information will be required in Quarterly Reports

a. Budget- HAF participants will be required to report cumulative to date Obligations and 

Expenditures relative to their HAF Grantee Plan.

b. Homeowner Applications- HAF participants will be required to report on metrics around 

received and approved unique Homeowner applications. More specifically, HAF 

participants will be asked to report on the following metrics regarding applications with each 

question disaggregated by the categories such as race, ethnicity, gender and income 

AMI%:

• Number of unique Homeowners that submitted a HAF application;

• Number of unique Homeowners that have submitted a completed HAF application;

• Number of unique Homeowners that submitted a draft or completed HAF application 

that was then subsequently withdrawn by the Homeowner;

• Number of unique Homeowners whose application was approved;

• Number of unique Homeowners whose application was denied;

o Disaggregation of denial separated by reason category. The categories are 

as follows: income eligibility, lack of COVID related financial hardship, 

property not the primary residence, principal balance exceeded conforming 

loan limit, application not completed within program timeframe and other to 

include a narrative.

• Number of unique Homeowners who applied for assistance that had previously received 

HAF assistance; and,

• Number of unique Homeowners that received assistance on more than one application.

c. Targeting- HAF participants will be required to report on targeting metrics including the 

following:

• The number of unique Homeowners that received HAF assistance;

• The number of unique Homeowners that received HAF assistance and were at or below 

100% Area Median Income (AMI) or United States Median Income (USMI) (whichever 

is greater/the HAF participant opted for in order to administer assistance); and,

• The number of unique Homeowners that received HAF assistance and were classified 

as a “Socially Disadvantaged Individual” (SDI).14

HAF participants will be asked to disaggregate these metrics by the categories noted under 

the Disaggregated Information requirement below.15

d. Delinquencies- HAF participants will be required to report on the number of Delinquencies 

resolved using HAF assistance. Delinquencies can be resolved through two forms of HAF 

assistance: Monetary or Non-Monetary. Delinquencies resolved through Monetary HAF 

14 Tribal Governments and the Department of Hawaiian Home Lands will not be asked to report on the 

number of unique Homeowners that received HAF assistance and were classified as a “Socially 

Disadvantaged Individual.”

15 Tribal Governments and the Department of Hawaiian Home Lands will not be asked to 

disaggregate targeting data.
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assistance includes direct support to homeowners, such as mortgage payment assistance, 

to resolve a Delinquency. Delinquencies resolved through Non-Monetary HAF assistance

includes indirect support, such as housing counseling, to resolve a Delinquency. HAF 

participants are expected to track the number of Delinquencies reduced as a result of HAF 

assistance and its category (Monetary or Non-Monetary) at the participant-level and 

program-level.

e. Reimbursement- HAF participants will provide information on any reimbursement 

expense(s) and the associated program design element that the reimbursement expense(s)

is/are linked to. 

f. Program(s) Information- HAF participants will provide information on all HAF funded 

programs. Programs are new or existing eligible government services or investments 

funded in whole or in part by HAF funding. For each program, the HAF participant will be 

required to enter the following information:

• Program Name;

• Identification Number;

• Program Start Date;

• Program Description;

• Program Design Elements Covered (selected by the HAF participant);

• Total Obligations Cumulative to Date;

• Total Expenditures Cumulative to Date;

• Number of Homeowners Assisted Cumulative to Date;

• Number of SDIs Assisted Cumulative to Date16;

• Number of Delinquencies Resolved with Non-Monetary and Monetary HAF Assistance

Cumulative to Date;

• Program Income Earned; and,

• Program Income Expended.

g. Expenditures- HAF participants are required to report the HAF assistance expended or 

spent by the HAF participant. HAF participants will be asked to report expenditures on a 

cumulative basis on at the following levels: the participant-level, program-level, and 

program design element-level. At the participant-level, HAF participants will be asked to 

disaggregate expenditures or amounts expended by the categories noted under the 

Disaggregated Information requirement below.17

h. Obligations- HAF participants are required to report the HAF assistance obligated. HAF 

participants will be asked to report obligations on a cumulative basis at the participant-level, 

program-level, and program design element-level. HAF participants will be asked to 

disaggregate participant-level obligations by the categories noted under the Disaggregated 

Information requirement below.18

i. Program Design Elements Covered- HAF participants will report on each of their Programs’ 

program design elements. HAF participants will create a new line item for each program 

design element and tie the program design element to a specific program. HAF participants 

will be expected to report the following for each specific program design element within a 

program: 

16 Please note, Tribal Governments and the Department of Hawaiian Home Lands will not be required 

to report on Program SDIs assisted.

17 Please note, Tribal Governments and the Department of Hawaiian Home Lands will not be required 

to disaggregate information related to Expenditures.

18 Please note, Tribal Governments and the Department of Hawaiian Home Lands will not be required 

to disaggregate information related to Obligations.
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• Total Obligations Cumulative to Date;

• Total Expenditures Cumulative to Date;

• Number of Homeowners Assisted Cumulative to Date; and,

• Number of SDIs Assisted Cumulative to Date.19

j. Disaggregated Information- HAF participants are expected to know how their HAF 

assistance has impacted different demographics in addition to other categories. This 

information will help determine equity indicators and confirm that HAF participants are 

reaching the appropriate population with HAF assistance. HAF participants will report on 

the following disaggregated categories at the participant-level for the number of unique 

Homeowners that received HAF assistance, the number of unique Homeowners classified 

as SDIs that received HAF assistance, the amount of HAF assistance obligated, and the 

amount of HAF assistance expended:

• Race

• Ethnicity

• Gender

• Area Median Income Level

• Socially Disadvantaged

• Region

• Mortgages

• Housing Type

• Zip Code

More information on the distinct breakdown of these disaggregated categories and the sublevels can be found in Appendix 1 and Appendix 2.

Compliance Information Requirements

The following compliance information will be required in Quarterly Reports:

k. Socially Disadvantaged Individual Definition – HAF participants will need to confirm the 

definition they used for a “Socially Disadvantaged Individual” (SDI) during the report 

quarter. The SDI definition will be pulled from the HAF participant’s HAF plan. If a HAF 

participant has changed or needs to adjust their definition of an SDI, they will select ‘deny’ 

from in the form and write their new SDI definition in the text box provided.20

The below questions are Compliance Information regarding Self-Disclosure of Improperly 

Funded HAF Assistance

Note: Using the questions below, determine if HAF assistance was improperly funded. 

Additionally, please provide detail on how it was identified and what remedial measures 

were/are being taken to address the issue and ensure it doesn’t happen again.

l. Maximum Conforming Loan Limit – HAF participants will need to report if they have used 

HAF assistance to assist homeowners with loans above the maximum conforming loan limit 

as defined in the HAF statue, section 3206(b)(1). If a HAF participant answers in the 

19 Please note, Tribal Governments and the Department of Hawaiian Home Lands will not be required 

to report on Program Design Element SDIs assisted.

20 Tribal Governments and the Department of Hawaiian Home Lands will not be asked to confirm their 

“Socially Disadvantaged Individual” Definition
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affirmative, they will need to provide an explanation about why they did assist homeowners 

with loans above the maximum conforming loan limit.

m. Written Attestations – HAF participants will need to report if they required homeowners to 

provide attestations about financial hardship prior to disbursing HAF assistance. If the HAF 

participant answers in the negative, they will need to provide an explanation about why they 

did not require or receive attestations from homeowners.

n. Annual Income – In determining income for each household applying for HAF assistance, 

HAF participants will need to report if they used HUD’s definition of “annual income” in 24 

CFR 5.609 (https://www.govinfo.gov/content/pkg/CFR-2021-title24-vol1/pdf/CFR-2021-

title24-vol1.pdf) or adjusted gross income as defined for purposes of reporting on IRS 

Form 1040 series as mentioned in the HAF guidance. If the HAF participant answers in 

the negative, they will need to provide an explanation about why they did not use HUD’s 

definition of “annual income” in 24 CFR 5.609 or adjusted gross income as defined for 

purposes of reporting on IRS Form 1040 series as mentioned in the HAF guidance.

o. Targeting AMI/USMI Dollar Amount – HAF participants will need to report the dollar amount 

Obligated to homeowners with incomes less than the greater of 100% AMI or US Median 

Income.

p. Targeting AMI/USMI Assistance – HAF participants will need to report if they allocated at 

least 60% of HAF assistance to homeowners with incomes less than the greater of 100%

Area Median Income or US Median Income. If the HAF participant answers in the negative, 

they will need to provide an explanation about why they did not allocate at least 60% of 

HAF assistance to homeowners with that income threshold.

q. Certifications – HAF participants will need to read, review, and sign all relevant certifications 

in the Quarterly Report on Treasury’s reporting portal. By signing the certifications, the 

authorized representative for the HAF participant is confirming that the HAF participant is 

in compliance with all terms from the HAF statute, HAF Guidance, and HAF Financial 

Assistance Agreement and that the HAF participant has answered all questions truthfully.

Required Components of Standard Financial Reporting (SF-425)

All HAF participants must submit the corresponding contents of the Federal Financial Report, 

Standard Form 425 (SF-425), on a quarterly basis. Treasury uses the financial data to 

compare the rate of the participant’s actual expenditures against performance data to verify 

that expenditure amounts align with program activities.

Annual Performance Report

Executive Summary

HAF participants will be asked to provide a high-level overview of their intended and actual 

uses of funding including, but not limited to the following: the HAF participant’s plan for use of 

funds to promote a response to the pandemic and economic recovery, key outcome goals, 

progress to date on those outcomes, and any noteworthy challenges or opportunities identified 

during the reporting period.

Annual Performance Reporting

The following HAF participants are required to submit Annual Performance Reports: 

• States

• The Department of Hawaiian Home Lands

• Tribal Governments 
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HAF participants are required to submit an Annual Performance Report on an annual basis 

and demonstrate the impact of the HAF-financed programs. Reports should include data 

related to program outputs and outcomes against the stated objectives of the HAF participant’s 

HAF Grant Plan. 

Report Period Covered Due Date

1 Award Date – June 30, 2022 Monday, August 15, 2022

2 July 1, 2022 – June 30, 2023 Tuesday, August 15, 2023

3 July 1, 2023 – June 30, 2024 Thursday, August 15, 2024

4 July 1, 2024 – June 30, 2025 Friday, August 15, 2025

5 July 1, 2025 – June 30, 2026 Monday, August 17, 2026

6 July 1, 2026 – June 30, 2027 Monday, August 16, 2027

Each Annual Performance Report must be posted on the public-facing website of the HAF 

participant on or by the same date the HAF participant submits the report to Treasury. The 

Annual Performance Report will include, at a minimum, the following information: 

Community Engagement

HAF participants will provide an update on how the HAF participant planned or current use of 

funds incorporates written, oral, and other forms of input that capture diverse feedback from 

constituents, community-based organizations, and the communities themselves. Where 

relevant, this description must include how funds will build the capacity of community 

organizations to serve people with significant barriers to services, including people of color, 

people with low incomes, limited English proficient populations, and other traditionally 

underserved groups. 

Performance Goals

HAF participants initially submitted performance goals on use of HAF awarded funds in their 

approved Grantee Plan. Each one of the performance goals should have identified how the

HAF participant will address homeowner needs and should have been disaggregated by key 

characteristics such as mortgage type, racial and ethnic demographics, and/or geographic 

areas, as appropriate. HAF participants will be required to provide a status update and 

quantitative measures, if applicable, on each of their initial performance goals set forth in their 

Grantee Plan. Please note, HAF participants will not have the ability to alter their original 

performance goals noted in their Grantee Plan nor add additional performance goals in the 

Annual Report.

Methods for Targeting and HAF Funding

HAF participants were asked in their original Grantee Plan to describe how the HAF 

participant will effectively target HAF award funds to (1) homeowners with 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; and (2) socially disadvantaged 

individuals. The description included the HAF participant’s targeting strategies. HAF 

participants will be required to provide an update on their targeting methods and if they have 

appropriately executed targeting methods according to their original Grantee Plan.

Best Practices and Coordination with Other HAF participants

HAF participants will be required to describe any relevant coordination with federal agencies 

including FHA, VA, and USDA, as well as with state or local agencies that hold mortgage 

portfolios that have covenants or targeting requirements that match the HAF participants’ 

HAF targeting strategies and goals.
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Budget by Program Design Element (if adjusting)

HAF participants will need to validate current program design element budget expended to 

date against their original projected budget amounts. The Annual Report will have the 

Grantee Plan budget amounts prepopulated for each program design element. HAF 

participants are expected to adhere to these budget amounts unless they have submitted a 

request for Grantee Plan change and the request has been formally accepted by Treasury.

Civil Rights Compliance

Treasury may request information on the HAF participant’s compliance with Title VI of the Civil 

Rights Act of 1964 on an annual basis. This information may include a narrative describing 

the HAF participant’s compliance with Title VI, along with other questions and assurances. 

This collection does not apply to Tribal Governments.
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Appendix 1 – Race, Ethnicity and Gender Categories

The following is a list of race, ethnicity, and gender categories for HAF participant data 

collection and reporting.

Race

American Indian or Alaska Native

Asian

Indian 

Chinese

Filipino

Japanese

Korean

Vietnamese

Asian (Other)

Black or African American

Native Hawaiian or Other Pacific Islander

Guamanian or Chamorro

Native Hawaiian

Samoan

Pacific Islander (Other)

White

Declined to Answer

Data Not Collected

Ethnicity

Hispanic or Latino/a

Not Hispanic or Latino/a

Declined to Answer

Data Not Collected

Gender

Female

Male

Nonbinary

Declined to Answer

Data Not Collected
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Appendix 2 – Targeting Categories

The following are key targeting categories for HAF participant data collection and reporting.

Income: Area Median Income 

Below or equal to 50%

Greater than 50% and less than or equal 80% 

Greater than 80% and less than or equal to 100%

Greater than 100% and less than or equal to 150%

Data Not Collected

Socially Disadvantaged 

Racial or Ethnic Prejudice – member of a group that has been subjected to racial or 

ethnic prejudice or cultural bias within American society.

Majority-Minority Census Tract – resident of a majority-minority Census tract.

Limited English Proficiency – individual with limited English proficiency.

Resident US Territory, Indian Reservation, or Department of Hawaiian Home Lands –

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

Lands.

Persistent Poverty County – individual who lives in a persistent-poverty county, 

meaning any county that has had 20% or more of its population living in poverty over 

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

Other – individual in accordance with a process developed by a HAF participant for 

determining whether a homeowner is a socially disadvantaged individual in 

accordance with applicable law, which may reasonably rely on self-attestations.

N/A – individual was not classified as Socially Disadvantaged.

Region

Urban – Only geographic areas delineated as “Urbanized Areas” by the Census 

Bureau’s 2010 Urban and Rural Classification Criteria. This definition does not 

include the Census Bureau’s 2010 list of “Urban Clusters.” HAF participants should 

use the following Census Bureau “Urbanized Areas” list here to determine if

Homeowners are located in an urban region.

Rural – Includes all geographical areas not included in the urban definition above.

Data Not Collected

Mortgages

Federal Housing Administration (FHA) 

Department of Veterans Affairs (VA)

U.S. Department of Agriculture (USDA)

Government Sponsored Enterprise (GSE)

Private-label Securities

Reverse Mortgages

Portfolio Loan
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Land Contracts

N/A

Data Not Collected

Housing Type

Single Family Home Detached

Single Family Home Attached

Condominium

Manufactured Housing

Other

Data Not Collected

Zip Code

HAF participants will be expected to collect number of Homeowners and program 

funds Obligated and Expended at the zip code level. 
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Appendix 3 – Program Design Element Categories

The following is a list of program design elements for HAF participant data collection and 

reporting.

Program Design Elements

Mortgage Payment Assistance – mortgage payment assistance.

Financial Assistance – 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.

Mortgage Principal Reduction – mortgage principal reduction, including with respect 

to a second mortgage provided by a nonprofit or government entity.

Facilitating Interest Rate – facilitating mortgage interest rate reductions.

Payment Assistance Utilities – payment assistance for homeowner’s utilities, 

including electric, gas, home energy (including firewood and home heating oil), water, 

and wastewater.

Payment Assistance Internet – payment assistance for homeowner’s internet service, 

including broadband internet access service, as defined in 47 CFR 8.1(b).

Payment Assistance Insurance – payment assistance for homeowner’s insurance, 

flood insurance, and mortgage insurance.

Payment Assistance Fees – payment assistance for homeowner’s association fees 

or liens, condominium association fees, or common charges, and similar costs 

payable under a unit occupancy agreement by a resident member/shareholder in a 

cooperative housing development.

Payment Assistance Loans – payment assistance for down payment assistance 

loans provided by nonprofit or government entities.

Payment Assistance Taxes – payment assistance for delinquent property taxes to 

prevent homeowner tax foreclosures.

Measures Preventing Displacement – measures to prevent homeowner 

displacement, such as home repairs to maintain the habitability of a home, including 

the reasonable addition of habitable space to alleviate overcrowding, or assistance to 

enable households to receive clear title to their properties.

Counseling or Education – counseling or educational efforts by housing counseling 

agencies approved by HUD or a tribal government targeted to households eligible to 

be served with funding from the HAF related to foreclosure prevention or 

displacement.

Legal Services – legal services targeted to households eligible to be served with 

funding from the HAF related to foreclosure prevention or displacement.