12.20.21 IHCDA HAF Term Sheet Summary of Changes and Clarification Responses

12.20.21: Removed requirement to submit proof of bankruptcy discharge from applicants that have 

previously filed for bankruptcy. This requirement was removed from all Term Sheets. 

1) Your program guidelines contain a requirement that homeowners who have previously filed for 

bankruptcy must provide proof of court ordered discharge or dismissal. Does this requirement 

apply to all homeowners who have filed for bankruptcy at any point in time or does it only apply 

to homeowners who have recently filed for bankruptcy? And if so, how recent?

After internal discussion, IHCDA has elected to modify its documentation requirements for applicants 

who have previously filed for bankruptcy. IHCDA will no longer require proof of court ordered 

“discharge” or “dismissal” from these applicants. Instead, IHCDA will treat applicants on a case-by-case 

basis and allow servicers/lenders to determine when proof of discharge is required. If a servicer/lender 

requires this documentation to move forward, a counselor or case manager will reach out to the 

homeowner to request the appropriate documentation. Additionally, IHCDA will still allow applicants to 

submit this documentation at the time of application (with a notice that doing so could help avoid delays 

in their application review) but doing so will be optional, not a requirement. IHCDA believes this policy 

change will improve the efficiency of the application process and ensure applicants are not discouraged 

from applying due to burdensome documentation requirements. IHCDA is also prepared to modify its 

policy if it becomes clear that reviewing applicants on a case-by-case basis is causing delays. In this 

situation, IHCDA would modify its policy to require proof of discharge for any homeowner that has filed 

for bankruptcy in the previous two years. However, IHCDA intends to start with the least burdensome 

requirement possible and will only modify this policy if it becomes clear doing so is necessary. Updated 

term sheets have been uploaded to the Treasury Portal that reflect this change. 

2) Given that your program is excluding homeowners who have a land contract instead of a 

mortgage, has there been analysis undertaken to identify the proportion of these homeowners in 

the state of Indiana? If Indiana identifies significant need among this population, will it 

reconsider its exclusion of these homeowners?

Because land contracts were ineligible for IHCDA’s HHF program as well, IHCDA does not have an 

exact number of homeowners that applied for HHF but were deemed ineligible because they had a land 

contract. These homeowners usually received assistance outside of the HHF program through IHCDA’s 

existing IFPN network, therefore, they were never entered into IHCDA’s HHF system. However, after 

discussion, IHCDA staff estimates that no more than 5% of applicants, over the course of the entire HHF 

program, had land contracts. To ensure more specific data is available for HAF, IHCDA will include a 

question in the HAF application portal asking whether the applicant has a land contract. This will allow 

IHCDA to track and analyze metrics specifically related to land contracts. If it becomes clear that there is 

a significant need among this population, IHCDA is willing to entertain multiple options to assist them 

including offering housing counseling to these individuals outside of the HAF program through its IFPN 

network or reconsidering its exclusion of these homeowners from the HAF program itself.