1

HAFP-0092-State of Virginia

Treasury Feedback for Resubmission of Plan

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

Completeness

 Community Engagement

o Using the fields provided in the portal, please submit list of housing counseling 

servicesorganizations that provided input for your plan.

Virginia Housing Response:

1. As further described below, Virginia Housing has a long-standing commitment to supporting 

housing counselors, including a commitment in FY 22 of $3.5 million of Virginia Housing’s own net 

assets to support housing counselors. Prior to submitting its HAF Plan to Treasury, Virginia 

Housing solicited comments and publicized its public hearing and draft plan in a number of ways, 

all as described in the Plan. Specific to housing counselors, this included e-mailing a draft of the 

Plan to approximately 200 individual housing counselors at the agencies listed below. Virginia 

Housing received only a couple of comments from the e-mail recipients prior to submitting the 

Plan on August 17, 2021.

Provider

Name

Provider

Address

Provider Website Provider Primarily

Serves LMI

Households

Provider

Addresses

Impacts of

Housing

Discrimination

AccomackNorthampton 

Planning District 

Commission

23372 Front Street

Accomac, Virginia 

23301

https://www.a-npdc.org/accomacknorthampton-planning-district-commission/

☐ ☐

Appalachian 

Community Action 

& Development 

Agency, 

Inc.(AppCAA)

175 Military Lane, 

Gate City, VA 24251

https://appcaa.org/ ☒ ☐

Blue Ridge Housing 

Network

134-A Peyton Street 

– Front 

Royal, VA 22630

http://blueridgehousingnetwork.org/ ☒ ☐

Catholic Charities of 

Eastern Virginia, 

Inc.

5361 Virginia Beach 

Blvd.

Virginia Beach, VA 

23462

https://cceva.org/services/financial-housingcounseling/

☐ ☒

Central Virginia 

Housing Coalition

2300 CHARLES 

STREET, 

FREDERICKSBURG, VA 

22401

https://centralvahousing.org/ ☒ ☐

centro de apoyo 

Familiar

6231 Leesburg Pike, 

Suite 410 Falls Church, 

VA 22044

https://mycaf.org/ ☒ ☐

Child & Family 150 W. Boush Street, https://www.theupcenter.org/ ☐ ☐
2

Services of Eastern 

Virginia d/b/a The 

Up Center

Ste. 500

Norfolk, VA 23510

Commonwealth 

Catholic Charities

1601 Rolling Hills 

Drive, Richmond, VA 

23229

https://www.cccofva.org/ ☒ ☐

Community 

Housing Partners

48 Depot Street NE

Christiansburg, VA 

24073

https://www.communityhousingpartners.org/ ☒ ☒

Cornerstones 11150 Sunset Hills 

Road, Suite 210

Reston, VA 20190

https://www.cornerstonesva.org/ ☒ ☐

Danville 

Redevelopment and 

Housing Authority

35 Jones 

CrossingDanville VA 

24541

https://www.drhava.com/ ☒ ☒

First Home Alliance 3138 Golansky Blvd, 

Suite 202

Woodbridge, VA 

22192

https://firsthomealliance.org/ ☒ ☐

Hampton 

Redevelopment 

Housing Authority

1 Franklin Street

Suite 603

Hampton, VA 23669

http://www.hamptonrha.com/ ☒ ☒

Hampton Roads 

Community Action 

Program, Inc.

2410 Wickham 

Avenue, Newport 

News, VA 23607

https://hrcapinc.org/ ☒ ☒

Helping Overcome 

Poverty's Existence

680 West Main Street

Wytheville, VA 24382

https://www.wythehope.org/ ☒ ☒

Housing 

Opportunities 

Made Equal of 

Virginia, Inc. 

(HOME)

626 East Broad Street, 

Suite 400

Richmond, VA 23219

https://homeofva.org/ ☒ ☒

James City County 101 Mounts Bay Road

Williamsburg, VA 

23185

https://www.jamescitycountyva.gov/ ☐ ☐

Korean Community 

Service Center of 

Greater 

Washington

7700 Little River 

Turnpike #406, 

Annandale, VA 22003

http://www.kcscgw.org/ ☐ ☐

Latino Economic 

Development 

Corporation of 

Washington, DC

2300 9th Street South, 

Suite 300 B

Arlington, VA 22204

https://www.ledcmetro.org/ ☐ ☐

Lynchburg 

Community Action 

Group, Inc.

1010 Main St, 

Lynchburg, VA 24504

https://lyn-cag.org/ ☒ ☒

New River 

Community Action, 

Inc.

1093 E Main St, 

Radford, VA 24141

https://newrivercommunityaction.org/ ☒ ☒

Norfolk 

Redevelopment & 

Housing Authority -

HomeNet 

Homeownership 

Center

555 E Main St, 

Norfolk, VA 23510

http://www.nrha.us/ ☒ ☐

Northern Virginia 

Family Services

10455 White Granite 

Dr #100, Oakton, VA 

22124

https://www.nvfs.org/ ☒ ☐
3

People 

Incorporated of 

Virginia

1173 W Main St, 

Abingdon, VA 24210

https://www.peopleinc.net/ ☒ ☒

Piedmont Housing 

Alliance

682 Berkmar Cir, 

Charlottesville, VA 

22901

https://piedmonthousingalliance.org/ ☒ ☒

Quin Rivers, Inc. 

dba Thrive Virginia

7911 Courthouse Cir, 

New Kent, VA 23124

https://thriveva.org/ ☒ ☐

Skyline Community 

Action Partnership

532 S Main St, 

Madison, VA 22727

http://skylinecap.org/ ☒ ☒

Southeast Rural 

Community 

Assistance Project, 

Inc

347 Campbell Ave SW, 

Roanoke, VA 24016

http://www.southeastrcap.org/ ☒ ☒

Southside 

Community 

Development & 

Housing 

Corporation

1624 Hull St, 

Richmond, VA 23224

https://www.scdhc.com/ ☒ ☒

Southside Outreach 

Group

1425 Seymour Dr, 

South Boston, VA 

24592

https://www.ssorg.org/ ☒ ☐

STOP Inc 5700 Thurston Ave 

STE 101, Virginia 

Beach, VA 23455

https://www.stopinc.org/ ☒ ☒

Suffolk 

Redevelopment and 

Housing Authority

530 E Pinner St, 

Suffolk, VA 23434

https://www.suffolkrha.org/ ☒ ☒

Telamon 

Corporation

808 Moorefield Park 

Drive #106, State 

Office - Virginia, 

Richmond, VA 23236

https://www.telamon.org/ ☒ ☒

Total Action Against 

Poverty D/B/A Total 

Action For Progress

302 2nd St SW, 

Roanoke, VA 24001

https://tapintohope.org/ ☒ ☐

Urban League of 

Hampton Roads, 

Inc.

7300 Newport Avenue

Norfolk, VA 23505

https://ulhr.org/ ☒ ☒

Virginia 

Cooperative 

Extension - Prince 

William County

8033 Ashton Avenue, 

Suite 105

Manassas, VA 20109-

8202

https://prince-william.ext.vt.edu/ ☐ ☐

Volunteers of 

America 

Chesapeake, 

Incorporated

7901 Annapolis Road

Lanham, MD 20706

https://www.voachesapeake.org/ ☒ ☐

2. Recognizing the tight deadline Virginia Housing had given counselors to comment on the Plan and 

Virginia Housing’s desire for input from counselors, Virginia Housing held a work session with the 

housing counselors on September 17, 2021, after Plan submission. Virginia Housing invited 

representatives of all Virginia HUD-approved housing counseling agencies and HUD’s Office of 

Housing Counseling to that session. Of the sixty-nine individuals invited, fifty accepted and 

attended the session. At this session, the feedback on the Plan from the counselors was 

overwhelmingly positive and they viewed the VMRP reinstatement program as an additional tool in 

their toolbox. On October 12, 2021, Virginia Housing also held an information session with Centro 

de Apoyo Familiar or Center for Assistance to Families (CAF), a non-profit, HUD approved 

comprehensive Housing Counseling Agency. Virginia Housing also recognizes that additional 
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guidance will be needed for the counselors to assist customers, and Virginia Housing anticipates 

holding additional sessions with the counselors once the Plan is approved and the at-large VMRP 

program is initiated.

3. As the VMRP Pilot has been rolled out, housing counselors have proven to be an asset in already 

assisting a couple of customers with the completion of their applications.

o Using the fields provided in the portal, please submit list of community

organizationsthat provided input for your plan.

Virginia Housing Response:

Organization

Name

Organization

Address

Organization Website Organization

Primarily ServesLMI

Households

Provider

Addresses

Impacts of

Housing

Discrimination

Latino Economic 

Development 

Corporation of 

Washington, DC

2300 9th Street South, 

Suite 300 B

Arlington, VA 22204

https://www.ledcmetro.org/ ☒ ☐

Virginia Realtors 10231 Telegraph 

Road, Glen Allen, VA 

23059

https://virginiarealtors.org/ ☐ ☐

 Your plan lists Patrick Carey as the Authorized Official, while the original application for HAF

payments was signed by Llew Anderson. To ensure prompt payment upon approval, the

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

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

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

Virginia Housing Response: Pat Carey was the initial authorized official. Due to his impending

retirement, Llew Anderson is now the Authorized Official for Virginia Housing listed in the 

portal.
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Homeowner Needs and Community Engagement

Data

 No questions.

Community Engagement and Public Participation

 Your plan notes public input and community engagement in the plan development process.

Please explain how community engagement informed your plan’s programmatic and outreach

design.

Virginia Housing Response: As described in the Plan, Virginia housing conducted numerous 

meetings and employed various communication vehicles to inform and engage with housing 

advisory committees, community-based organizations, legal services providers, housing 

counseling agencies, and the general public. The overwhelming feedback was that mortgage 

reinstatement and payment assistance constituted the greatest need across the state. 

Additionally, through public feedback and receipt of additional Treasury guidance published 

in August, Virginia Housing made a number of updates to the draft Plan to finalize the Plan 

for submission to Treasury. See pages iii – viii of the Plan, which list those changes in detail. 

https://dc29f985-b871-449c-a8d1-

05aa7856e4c9.filesusr.com/ugd/00c607_5b38ac34d3c6410285940100c370c713.pdf

For example, Virginia Housing learned of additional need related to condominium special 

assessments and updated the eligible list of expenditures under VMRP to include special 

assessments. 

 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, 

andwhether you have responded to the comments

Virginia Housing Response: Since submitting the HAF Plan, Virginia Housing has received the 

following additional public comments:

1. Duplicative comments, including from the same individuals listed in the Plan, disagreeing 

with Virginia Housing’s responses to public comments set forth in the Plan (for the same 

reasons stated in the initial comments);

2. Individuals expressing a desire for the VMRP Pilot Program to be open to individuals in 

addition to the Virginia Housing serviced loan portfolio; and

3. Individuals expressing dissatisfaction that the VMRP at-large program has not yet been 

opened because Treasury approval is still pending. We have over 1,000 people that 

have signed up to receive notice of the opening of the at-large program.

Virginia Housing has responded to all comments received.

Ongoing Assessment of Homeowner Need

 No questions.
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Program Design

 Please explain how the sources of data listed in the section on Homeowner Needs

informed which Program Design Elements to include in your plan.

Virginia Housing Response: Twenty five percent of homeowners within Virginia qualify as socially 

disadvantaged based on race/ethnicity, as defined by the U.S. Treasury. According to CHAS data, 

34% of Virginia homeowners are considered at or below 100% of the area median income. The 

median household income in Virginia, according to Census ACS, is $74,222 and median home 

value is $367,200 according to Virginia Realtors. Based on the CoreLogic data, 5.5% of loans are in 

delinquency throughout Virginia. Out of 580,034 loans in the CoreLogic sample, 5.2% are in 

forbearance.

Virginia Housing has analyzed demographics, economic conditions, and risk factors for housing 

instability for the entire state at the county, census tract, and ZIP Code level. The level of 

investigation was determined by the availability of data sources. Virginia Housing concluded, 

based on available datasets, that ZIP Code level aggregation provides the most comprehensive 

coverage of key decision factors for the VMRP. While ZIP Code level aggregation of data was 

available from multiple sources, it was our conclusion that the detailed loan performance data 

secured from third-party housing provider CoreLogic was the most comprehensive and applicable 

to the Virginia Housing prioritization methodology. While the Virginia Housing loan portfolio 

dataset provides comparable loan performance information at ZIP Code level, there are known 

differences in some loan variables that make the CoreLogic data more suitable for application to 

all Virginia loans. 

Virginia Housing used mathematical and statistical techniques to construct a common data 

workbook from the data analyses in an established format. This allowed rapid ranking and crosstabulation of demographic, income, and loan performance elements in a manner that directly 

supports decision-making for program design and implementation. To further facilitate decisionmaking, Virginia Housing constructed a web-based visualization platform that allows mapping of 

data at the ZIP Code level, based on the data elements that have been determined most 

significant. Virginia Housing staff use this shared data resource to evaluate specific questions and 

to explore additional scenarios. This visual analysis of the data can be undertaken one variable at 

a time or with multivariate views resulting from the layering of different data.

The resulting Virginia Homeowner Assistance Fund Need Index is a ZIP Code-level index that can 

be used to help estimate the likelihood that a ZIP Code will contain loans that are a high priority 

for servicing via the VMRP. This index considers four factors, based on the program’s eligibility 

criteria:

 Percent of Homeowners who are Socially Disadvantaged (source: U.S. Census Bureau’s 

American Community Survey (Census ACS) data)

 Percent of Homeowners <= 100% Area Median Income (source: United States Department of 

Housing and Urban Development (HUD) CHAS data)

 Percent of Homeowners in Delinquency (source: CoreLogic data)

 Percent of Homeowners in Forbearance (source: CoreLogic data)
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Applying the same methodology, in this case using the CoreLogic datasets with the larger 

loan performance portfolio, Virginia Housing uses the Weighted Index to rank and prioritize 

ZIP Codes at the highest loan risk and significant loan risk for targeted outreach.

A benefit of the ranking approach using the Weighted Index is that the associated data allows 

Virginia Housing to predict how far the allocated funds will potentially last when working through 

the ZIP Codes on the ranked list. Virginia Housing can calculate a count for each ZIP Code for 

loans with performance issues, assume an average disbursement per borrower, and a “fallout 

rate” for VMRP applications. Fallout is a term for the applicants that could be eligible for VMRP 

assistance that does not end up receiving a grant. There are typically various reasons for this, 

including that they never apply for help, they never fully complete the process, they turn out to 

be ineligible for other reasons, or they will not sign a grant agreement. Fallout rates in other 

federally funded grant programs such as CDBG-DR housing assistance, COVID Emergency Rental 

Assistance, and others can be significant – well over 50% in many cases. 

Combining this information allows Virginia Housing to determine how far down the ranked ZIP 

Code list that the allocated funding will last. This also allows some assurances of how much of the 

loan risk profile the VMRP will address. Currently, Virginia Housing projects that the average 

disbursement for each borrower in our planned Reinstatement Program will be $15,500. Using 

that assumption and an assumed allocation budget after funding and administration costs, the 

full VMRP would have approximately $206 million available for homeowner funding. Therefore, 

there would be funds available to disburse to roughly 13,290 Virginia borrowers with mortgages 

in arrears or forbearance. Using the data associated with the Weighted Index ranking, along with 

an assumed borrower fallout rate, it is possible to determine how many ZIP Codes for the highest 

risk loan categories would get covered with the available dollars.

Using the Weighted Index calculations that Virginia Housing has completed, and assuming a 

relatively conservative fallout rate of 50%, indications are that with $206 million of remaining

HAF funds a total of 161 high, significant, and moderate loan risk ZIP Codes could be assisted. This 

would cover all 131 of Virginia Housing’s priority one areas and approximately 10% of the 

“moderate risk” ZIP Code population as well. The utility for this use of the ranking construct is 

straightforward. The average disbursement could ultimately vary plus or minus, with a change in 

the corresponding numbers of ZIP Code areas potentially served. The actual fallout rate observed 

over time would impact the same way. If Virginia were to receive an additional HAF funding 

allocation over time, not only would more of the overall loan portfolio get attention, but Virginia 

Housing can further predict 1) how far additional funds will go for an existing program in delivery, 

and 2) what funding could be allocated against additional programs on Virginia Housing’s policy 

priority list

With high energy costs looming and known existing arrearages for low-income and elderly 

populations in the state, Virginia Housing undertook a serious analysis to determine whether HAF 

funding should be used to support utility assistance. Though data sources for utility arrearages 

and average costs were not obtainable, Virginia Housing did analyze the availability of existing 

utility assistance programs across the state. There are at least 29 different public and private 

sector water and energy assistance programs through which homeowners may receive utility 

relief. Because of the widespread coverage of these programs and the overwhelming need 

associated with mortgage (and associated homeownership cost) delinquency, the VMRP is 

operating programs for mortgage reinstatement, mortgage payment assistance, and other 
8

delinquent homeownership costs that pose the most immediate threat to Virginia homeowners’ 

ability to maintain ownership of their property.

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

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

need to be addressed under an expedited or prioritized timeline (e.g. HOA liens, tax 

delinquencies, utility shut off)?

Virginia Housing Response: The application process is designed to gather all relevant 

information about the applicant’s current housing situation, specifically the status of 

mortgage and homeownership costs that can pose an imminent threat to displacement. As a 

result of the program’s initial pilot activities, the VMRP application prescreen is being

modified to add a question related to foreclosure in progress. Applicants who answer “yes” 

to this question will trigger an expedited review. 

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

homeownersin evaluating loss mitigation options available for their mortgage. Your

descriptionshould include:

o whether your program will connect homeowners with housing counseling or

legalservices early in the process.

Virginia Housing Response: A link to housing counselors and legal aid service providers is 

available on our website www.VirginiaMortgageRelief.com to help individuals self-select 

into resources needed. Further, this information is provided to homeowners through the 

application and case management processes. Virginia Housing has also created a website 

www.StayHomeVirginia.com with information for homeowners on federal programs, 

housing counselors, foreclosure prevention and legal aid contacts. 

Apart from VMRP and not to be reimbursed by HAF funds, Virginia Housing is committed 

to providing Housing Counseling resources to support the Virginia HUD-approved Housing 

Counseling Network. Through a program utilizing Virginia Housing’s net assets, it has 

provided HUD-approved Housing Counseling Programs approximately $2.5 million 

annually. In FY22 we have increased our commitment to $3.5 million. The increase in 

funds is specifically to support housing counseling and education services to households 

facing housing instability such as eviction, default, foreclosure, or loss of income that 

caused or could cause eviction, default, foreclosure, or homelessness. 

Revised Response: A link to housing counselors and legal aid service providers is 

available on our website www.VirginiaMortgageRelief.com to help individuals self-select 

into resources needed. Further, this information is provided to homeowners through the 

application and case management processes. Virginia Housing has also created a website 

www.StayHomeVirginia.com with information for homeowners on federal programs, 

housing counselors, foreclosure prevention and legal aid contacts. 

Apart from VMRP and not to be reimbursed by HAF funds, Virginia Housing is committed 

to providing Housing Counseling resources to support the Virginia HUD-approved Housing 

Counseling Network. Through a program utilizing Virginia Housing’s net assets, it has 

provided HUD-approved Housing Counseling Programs approximately $2.5 million 
9

annually. In FY22 we have increased our commitment to $3.5 million. The increase in 

funds is specifically to support housing counseling and education services to households 

facing housing instability such as eviction, default, foreclosure, or loss of income that 

caused or could cause eviction, default, foreclosure, or homelessness. 

In response to discussions with Treasury, as further detail, the VMRP currently has 

program Option #2 permitting reinstatement plus additional prospective monthly 

payments for borrowers with housing expense to income ratio (HTI) above 40%. VMRP

also has processes to provide information on housing counselors and loss mitigation 

options to these individuals early in the pre-screen and application process. VMRP 

includes banners in the electronic pre-screen and application portal that notify applicants 

of housing counseling services and how to connect. The case management process 

typically includes discussions with homeowners very early in the process about ability to 

afford mortgage payments with available information for housing counseling services. In 

recognition of Treasury’s emphasis on referrals to housing counselors, the VMRP will 

create a referral notification to be sent by text, email, mail, and/or application portal 

posting specifically for applicants whose HTI exceeds 40% with contact instructions for 

finding housing counseling services to explore options that may help them continue to 

make future payments.

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

homeowners’ efforts at engaging in loss mitigation.

Virginia Housing Response: Housing counseling and legal services providers will support 

homeowners’ efforts at engaging in loss mitigation according to those entities’ own 

internal governing procedures, regulations, and processes. Virginia Housing will engage 

with HCAs and LSPs to ensure that providers have an understanding of HAF programming 

options, goals, and objectives and encourage such providers to undertake loss mitigation 

support to homeowners or VMRP applications, as those entities determine to be in the 

best interest of their clients. 

 In situations where the HAF assistance includes or will be limited to payments for

mortgagereinstatement, please explain whether and how your will assess whether a 

similar or more appropriate alternative loss mitigation option is available through the

servicer.

Virginia Housing Response: Loss mitigation options vary based on a number of homeownerspecific factors to which the servicer, not VMRP, is privy. VMRP staff members are not 

mortgage servicing professionals, trained housing counselors or attorneys, nor are they

affiliated with any particular servicer. As such they cannot assess, nor in Virginia Housing’s 

opinion should they, assess whether a similar or more appropriate loss mitigation option is 

available through the servicer. 

Our plan has a reinstatement option and reinstatement with monthly payments option for 

those who cannot make ongoing monthly payments. 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 also, as discussed above, information on 
10

housing counselors and legal service providers. This will allow homeowners to explore all 

options available to them prior to committing to use of one option or another. This will 

further allow homeowners to obtain the most accurate and timely information on loss 

mitigation should they choose to seek it from their servicer(s). Virginia Housing has also 

created a video series for homeowners, focused on Virginia Housing customers, which 

includes a video on loss mitigation options. A link to that video is on the Virginia Housing 

website and can be found here: 

https://www.youtube.com/embed/ZaASR3yJ_6g?rel=0&showinfo=0

VMRP does not require homeowners to pursue loss mitigation prior to applying for program 

assistance. Requiring homeowners to pursue loss mitigation options or prohibiting 

assistance to homeowners in loss mitigation would be an undue burden on the applicant. 

Also, servicers would likely be unable to keep up with demand for loss mitigation (as stated 

above, Virginia Housing estimates serving 13,290 household) and would cause a significant 

delay in the relief process, at a time when foreclosure may be imminent. 

 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?

Virginia Housing Response: See answer above. Also, applicants having already been through 

the loss mitigation process will not be eligible for VMRP, absent a subsequent eligible 

financial hardship.

 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?

Virginia Housing Response: Our HAF program is a reinstatement program and will not affect 

a homeowner’s monthly payment, however it can (i) reinstate the mortgage (Option 1); or 

(ii) reinstate the mortgage and make ongoing monthly payments (Option 2) in certain 

situations allowing homeowners to get back on their feet. The determination whether an 

applicant is eligible for Option 2 will be based upon their current debt-to-income ratio, 

which is an indication whether the monthly payment is sustainable. 

 Your programs set $30,000 as the maximum amount of assistance per homeowner.

Pleaseexplain how you determined this amount will be sufficient to resolve housingrelated delinquencies and whether the cap will be sufficient in areas with higher housing

costs?

Virginia Housing Response: The figure was based off the needs assessment considering 

number of likely eligible homeowners with delinquency, typical monthly mortgage payments 

for individuals having loans below conforming loan limits, and months of delinquency likely 

due to COVID. As stated above, Virginia Housing initially estimated the average claim would

be approximately $15,000. This has proven to be the case based on the Pilot program (see

the Pilot Program assistance statistics below). The $30,000 figure contemplates areas with 

high housing costs, such as NOVA.
11

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

thehomeowners that HAF will serve?

Virginia Housing Response: All indications are that home energy costs will increase in the 

coming months. However, Virginia Housing has analyzed the landscape of available home 

energy solutions available to Virginia homeowners throughout the state and determined 

that there are sufficient other resources available for help with utilities in Virginia.

Eligibility

 Please provide the rationale for establishing the following additional eligibility

requirementsspecified in your plan, including how you determined these requirements 

will not create unnecessary barriers to participation by eligible homeowners:

o That applicants that have been in a forbearance plan have not gone through the 

lossmitigation process with their servicer. In particular, please explain

 what criteria you will use to determine this eligibility requirement;

Virginia Housing Response: As stated above, Virginia Housing believes that a 

program requirement forcing applicants to first seek Loss Mitigation options 

through their servicers would be burdensome on both the homeowners and 

loan servicers, as well as creating substantial delays when time is of the 

essence, and therefore has excluded this as a requirement from the program 

design. 

While not requiring loss mitigation as a prerequisite to VMRP, Virginia 

Housing is supportive of homeowners exploring all available options. As 

stated above, Virginia Housing has created a video exploring loss mitigation 

options. Also, Virginia Housing has created a separate website 

www.StayHomeVirginia.com compiling resources for homeowners during the 

pandemic. With respect to the loans serviced by Virginia Housing, we have 

an active loss mitigation department to assist homeowners and Virginia 

Housing is in compliance with all investor (e.g. GNMA and Fannie Mae) and 

federal program requirements. As an example of the latter requirements, 

Virginia Housing is proud to originate or purchase 27% of all FHA loans in the 

Commonwealth of Virginia. As directed by HUD, Virginia Housing recently 

completed notifying eligible customers of HUD’s COVID-19 advance loan 

modification (ALM) program. Details of ALM are here: 

https://www.hud.gov/press/press_releases_media_advisories/HUD_No_21_

108 

While Virginia Housing is not requiring VMRP applicants seeking mortgage 

payment assistance to first seek loss mitigation relief from their loan servicer, 

the requirement that applicants that have been in a forbearance plan and 

gone through the loss mitigation process are not eligible is intended to be 

consistent with Treasury guidance recommending participants to avoid using 

HAF funds in a manner that replaces other loss-mitigation resources. Virginia 

Housing will be able to determine this eligibility requirement based on 

whether a delinquency exists because the loss mitigation would cure 
12

previously delinquent amounts. Even if a homeowner who had gone through 

loss mitigation were to apply, eligible VMRP expenses are defined to exclude 

a principal curtailment, such as paying down capitalized missed payments or 

a second lien resulting from loss mitigation.

However, these individuals may be eligible for future VMRP programs 

approved by Treasury in amendment(s) to this HAF Plan. (For example, if 

sufficient HAF funds remain after assisting applicants facing foreclosure, the 

VMRP could be amended, with Treasury approval, to assist individuals having 

had deferred payments added at the end of loan maturity or as subordinate 

liens.) 

Also, this eligibility requirement does not bar participation of homeowners in 

this situation from ever seeking assistance through VMRP. If a homeowner in 

this situation has experienced a subsequent COVID-related financial hardship, 

since exiting forbearance and loss mitigation, and they have again become 

delinquent on their obligations, they may apply for and receive VMRP HAF 

assistance for eligible VMRP expenses, assuming all other eligibility criteria 

are met.

Revised Response: As stated above, Virginia Housing believes that a program 

requirement forcing applicants to first seek Loss Mitigation options through their 

servicers would be burdensome on both the homeowners and loan servicers, as 

well as creating substantial delays when time is of the essence, and therefore has 

excluded this as a requirement from the program design. While not requiring loss 

mitigation as a prerequisite to VMRP, Virginia Housing is supportive of 

homeowners exploring all available options. As stated above, Virginia Housing has 

created a video exploring loss mitigation options. Also, Virginia Housing has 

created a separate website www.StayHomeVirginia.com compiling resources for 

homeowners during the pandemic. With respect to the loans serviced by Virginia 

Housing, we have an active loss mitigation department to assist homeowners and 

Virginia Housing is in compliance with all investor (e.g. GNMA and Fannie Mae) 

and federal program requirements. As an example of the latter requirements, 

Virginia Housing is proud to originate or purchase 27% of all FHA loans in the 

Commonwealth of Virginia. As directed by HUD, Virginia Housing recently 

completed notifying eligible customers of HUD’s COVID-19 advance loan 

modification (ALM) program. Details of ALM are here: 

https://www.hud.gov/press/press_releases_media_advisories/HUD_No_21_

While Virginia Housing is not requiring VMRP applicants seeking mortgage 

payment assistance to first seek loss mitigation relief from their loan servicer, 

Virginia Housing is including a provision in the VMRP Term Sheet that VMRP funds 

may not be used to pay down deferrals or partial claims that were part of an 

applicant’s previous loss mitigation . This provision is set forth in the eligible use of 

funds section rather than the program eligibility section. This provision is 

intended to be consistent with Treasury guidance recommending participants to 

avoid using HAF funds in a manner that replaces other loss-mitigation resources. 

Virginia Housing will be able to determine this eligibility requirement based on 

whether a delinquency exists because the loss mitigation would cure previously 
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delinquent amounts. Even if a homeowner who had gone through loss mitigation 

were to apply, eligible VMRP expenses are defined to exclude a principal 

curtailment, such as paying down capitalized missed payments or a second lien 

resulting from loss mitigation. 

However, these items may be payable from future VMRP programs approved by 

Treasury in amendment(s) to this HAF Plan. (For example, if sufficient HAF funds 

remain after assisting applicants facing foreclosure, the VMRP could be amended, 

with Treasury approval, to assist individuals having had deferred payments added 

at the end of loan maturity or as subordinate liens.) Also, this definition of eligible 

uses of VMRP funds does not bar participation of homeowners in this situation 

from ever receiving assistance through VMRP for eligible expenses. If a 

homeowner in this situation has experienced a subsequent COVID-related 

financial hardship, since exiting forbearance and loss mitigation, and they have 

again become delinquent on their obligations, they may apply for and receive 

VMRP HAF assistance for eligible VMRP expenses, assuming all other eligibility 

criteria are met.

 how the requirement will be communicated to homeowners that at the 

time they seek HAF assistance have not yet completed the loss mitigation 

processwith their servicer; and

Virginia Housing Response: There is no requirement under the VMRP that a 

homeowner must have completed the loss mitigation process with their 

servicer. 

 whether homeowners that have gone through the loss mitigation process be

able to access HAF ifloss mitigation does not result in a sustainable mortgage.

Virginia Housing Response: As stated above, the eligibility requirement that 

individuals having already gone through loss mitigation are ineligible does 

not bar participation of homeowners in this situation from ever seeking 

assistance through VMRP. If a homeowner in this situation has experienced 

a subsequent COVID-related financial hardship, since exiting forbearance 

and loss mitigation, and they have again become delinquent on their 

obligations, they may apply for and receive VMRP HAF assistance, assuming 

all other eligibility criteria are met.

The application is designed to assess whether a COVID-related financial 

hardship exists and the homeowner is in a current delinquency status. The 

current delinquency status is the indicator that loss mitigation did not result 

in a sustainable mortgage.

Outreach

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

limited English proficiency.
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Virginia Housing Response: The VMRP communications strategy focuses on the development and 

successful implementation of the VMRP’s goals of accessible marketing, mobile intake operations, 

and leveraging program champions.

- The VMRP team recognizes that the largest population of limited English proficiency in the 

Commonwealth are Spanish speakers. Per our research, we have identified the percentage of 

individuals that speak Spanish at home by county to support a targeted outreach and ensure we 

are relaying critical program messaging in the most appropriate languages based on community 

demographics. A total of 32 ZIP Codes were identified as having 5% or higher number of residents 

that speak Spanish at home. From this report, 11 ZIP Codes were identified as having 10% or 

higher number of residents that speak Spanish at home. Our out of home advertising (such as 

billboards, bus shelters, bus cards, etc.) and paid media will focus on key ethnic newspapers, radio, 

and other marketing venues that we know reach these key homeowner populations. 

- The VMRP team will offer communications and outreach materials in both English and Spanish and 

will use our zip code-based Needs Assessment to determine “out of home” advertising language 

needs. Marketing materials and the VMRP website, maintained by Virginia Housing 

Communications and Outreach staff, are or will be translated into Spanish. 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.

- The VMRP Call Center offers translation services for non-English speakers as well as TTY or other 

technology to assist people who are hearing impaired. The VMPR case management (CMs) team 

will also consist of bilingual CMs and administrative assistants to aid Spanish speaking applicants 

by phone, in writing, and during in-person intake meetings. In situations where a bi-lingual staff 

person is not available, the CMs will also use translation services via the phone.

- We will also use Virginia Housing’s existing relationships, as well as a comprehensive database of 

Virginia nonprofit organizations, as a starting point to identify, educate, and activate a network of 

community-based stakeholders to increase program reach and applicant support. This network 

will include program partners and community ambassadors. These components are instrumental 

to overall program success and to achieving the program’s goals of keeping Virginians at home.

- By leveraging local officials, community leaders, and partners in community-based and faith-based 

organizations with their own existing outreach and communications infrastructure from the outset 

we will be able to greatly amplify exposure of the program and increase intake of potential nonEnglish speaking applicants. 

- We also understand that some eligible participants may have limited access to internet or 

technology, so our communications approach will take into consideration a variety of channels and 

a broad geographical span to ensure that we reach all target audiences, through radio, billboards, 

transit, and other out of home advertising. Further, since submitting the Plan, Virginia Housing has 

determined that additional physical service center locations would be beneficial to these 

individuals. As such, in addition to a physical location in Newport News, Virginia Housing intends 

to open three additional locations – Richmond, Arlington and Wytheville (or other Southwest 

Virginia locality).
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- We have a proven strategy to overcome communication barriers, ensuring bilingual 

communication for customer service at all times and partnering with reliable language translation 

service to cover non-English speaking applicants’ communication requirements.

 Please explain how the program will provide culturally relevant marketing.

Virginia Housing Response: As noted above, the VMRP 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 VMRP. 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 VMRP 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. Community and ethnic 

organizations in particular, with their own existing outreach and communications infrastructure, 

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

- The VMRP 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 Virginia meet its 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

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

your program prioritize Socially Disadvantaged Individuals?

Virginia Housing Response: The VMRP has established priorities for funding where Priority 1 

will serve all homeowners who are below the 100% AMI threshold and socially 

disadvantaged individuals above 100% AMI and up to and including 150% AMI. Priority 2 

individuals are non-socially disadvantaged individuals above the 100% AMI threshold, but at 

or below the 150% threshold. No more than ten percent of each funding tranche is expected 

to be set aside for Priority 2 non-socially disadvantaged individuals, thus preserving 90% of 

funding for low income and socially disadvantaged households. Further, Virginia Housing will 

monitor expenditures to ensure that not less than 60% of HAF funds is used for qualified 

expenses that assist homeowners having incomes equal to or less than the 100% AMI 

threshold. [Note: All references to income thresholds reflect the full definitions in Treasury 

Guidance.]
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Performance Goals

 Please explain how you intend to communicate your progress towards performance to

the public.

Virginia Housing Response: VMRP will publish reports to the public-facing website.

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

yourprogram.

Virginia Housing Response: Number of homeowners served through mortgage 

reinstatement. Number of homeowners served through forward paying mortgage 

assistance. Number of homeowners assisted through qualified expense assistance.

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

Virginia Housing Response: Yes. The application has been designed to collect this 

information and can be reported against.

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

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

ofHAF funds to resolve the homeowner’s defaults or delinquencies.

Virginia Housing Response: We have considered adding this metric, but do not believe this 

will be feasible. Homeowners who do not receive HAF funding are not trackable by VMRP if 

they do not engage with the program or after they engage, but do not receive assistance. 

VMRP also has no authority over counseling and legal services agencies to demand reporting 

of their metrics for their services. However, Virginia Housing will request statistics from 

counseling and legal service providers related to number of homeowners assisted/

foreclosures prevented through their services but cannot guarantee that such information 

will be reported consistently or at all. 
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Readiness

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

includingstaffing, contractors, etc..

Virginia Housing Response: Virginia Housing’s internal management team has been working 

on the VMRP design and implementation since HAF funding was first announced. This team 

has remained stable with little to no turnover. Virginia Housing has augmented this team 

over time and appointed a dedicated Project Manager. Virginia Housing’s Project Manager is 

supported by other agency resources including legal counsel, quality control, 

communications, information technology, subject matter experts, and administration. 

Virginia Housing has contracted with a vendor to provide implementations support. That 

contractor has been supporting the agency since spring 2021. Together, Virginia Housing and 

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

services, an online application portal, and eligibility and payment services. This has included 

staffing up as volume of applicants is increasing.

The program has established overarching policies and procedures. Further, task level 

activities necessary to outreach, intake, eligibility, quality control, CDF transmission, and 

payment have been developed. The program has standard operating procedures for task 

level activities and is continuing 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.

A VMRP assistance center has been opened and staffed for applicants to receive in-person 

assistance. There are additional scheduled openings for centers across the state in advance 

of and concomitantly with Treasury approval of the HAF Plan and prior to full program 

launch.

Through operation of the Pilot Program, Virginia Housing is identifying process bottlenecks 

and gaps, formulating resolution, and implementing changes to increase efficiency. These 

program improvements are intended to create a system ready for full operation. 

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

tolaunch following approval?

Virginia Housing Response: Yes.

 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 ormade available to homeowners.

Virginia Housing Response: Virginia Housing intends to use the full initial 10% of funding for 

support of homeowner assistance grants, deferring all program startup costs including those 

identified for needs assessment and action plan development, contractor implementation, 

and VH administration costs until payment of the next tranche of funding. These costs and the 

costs of administering the balance of the HAF Funds, will not exceed the limit permitted by 

Treasury. The statistics on the pilot program are updated below:
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Number of households that have applied for assistance: 432

Number of households that have received funding: 18

Amount of funding disbursed: $249,757.25

Number of households eligible and estimated dollar value, pending CDF: 103 households, 

$1,389,954.68. *****Note that results of CDF process could change eligibility status and 

funding totals.
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Budget

 No questions.