1

HAFP-0107- State of Nebraska

Treasury Feedback for Resubmission of Plan

State of Nebraska Response

December 23, 2021

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

Completeness

• Your plan lists Philip Olsen as the Authorized Official, while the original 

application for HAF payments was signed by Governor Pete Ricketts. 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, 

please submit a request by email to HAF@treasury.gov.

Answer: Governor Ricketts letter dated December 15th, 2021 (attached) 

affirms Philip Olsen, State Accounting Administrator, as the authorized 

representative for the Homeowners Assistance Fund.

Homeowner Needs and Community Engagement

Data

• No questions

Community Engagement and Public Participation

• Please describe any coordination you intend with Tribes or Tribalentities.

Answer: We have reached out to all four tribal entities and plan to have 

regularly scheduled meetings with them to discuss the HAF program 

and share information and best practices. We will also establish a 

referral system for tribal members to access HAF funds from a Tribal 

entity when appropriate.

• Please provide an update indicating any public comments you have 

received since you submitted your HAF Plan, from which organization 

you received any such comment, and whether you have responded to 

the comments.
2

Answer: We have only received one additional public comment since 

submission of the HAF Plan. The comment was from Martha Marfileno at 

Buffalo County Community Partners, who asked if the application would 

be available in other languages besides English. She also suggested 

creating a checklist of all information and documents that applicants 

would need to bring with them when coming to an agency to receive 

assistance with completing the application. We responded to Martha 

that the application would be available in other languages, including 

Spanish, Vietnamese, and Russian. We have also created a checklist of 

items that an applicant will need to provide when applying for 

assistance.

Ongoing Assessment of Homeowner Need

• No questions

Program Design

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

Needs informed the Program Design Elements included in your plan.

Answer: The data from Black Knight (which purports to encompass 

75% of secondary market loans in the State of Nebraska), plus the data 

from the Nebraska Dept of Banking, as extrapolated, informed the 

determination to place the bulk of the program funds into 

reinstatements and forward payments. It appears that demand for 

reinstatements alone will outstrip the funds available to assist 

Nebraska homeowners. 

Title searches of selected properties in North and South 

Omaha validated the need for lien clearing programs. The State of 

Nebraska’s tax deed procedures put a significant number of nonmortgaged properties, generally owned by elderly people, at risk of tax 

foreclosure, thus creation of the Property Assistance Program was 

deemed appropriate. This program is anticipated to mainly serve 

socially disadvantaged populations. 

Data indicates many Nebraskans took advantage of the 

forbearance process and are in need of assistance to bring their 

loans current in order to move forward.
3

• 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?

Answer: The HAF application process includes a series of questions 

related to the homeowner’s financial condition, type of mortgage loan, 

and loss mitigation options provided by the servicing lender. 

Government insured loans and conventional loans backed by Fannie 

Mae and Freddie Mac will be flagged during the eligibility review 

process. A homeowner who continues to experience a financial 

hardship will be referred to a Nebraska based network of HUDapproved counseling agencies or legal aid services for assistance

working with the servicing lender to identify the best solution for the 

homeowner. There may be some situations where the homeowner is 

referred back to the HAF program as the best solution.

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

homeowner in determining whether a HAF-resolution will result in a 

sustainable monthlypayment?

Answer: In order to qualify for reinstatement assistance and possible 

forward monthly payment assistance, a homeowner must be employed 

or receive other income sources and provide an attestation of their 

ability to resume regular mortgage payments. If regular payments are 

not sustainable, the homeowner will be referred to a counseling agency 

or legal aid services.

• Are you anticipating increased winter home energy costs and their 

potential impact on the homeowners that HAF will serve?

Answer: NIFA is collaborating with the State of Nebraska for the 

overall coordination of ERAP. We communicate with utility providers 

periodically and the Department of Health and Human Services LIHEAP 

administrator for Nebraska. We are aware of the need and work to find 

solutions within the existing human services system. This human 

services system is further described under the Eligibility question. 
4

• Your programs set $30,000 as the maximum amount of assistance per 

homeowner. Please explain how you determined this amount will be 

sufficient to resolve housing-related delinquencies and whether the cap 

will be sufficient in areas with higher housingcosts?

Answer: Through extensive data collection efforts of both mortgage 

and escrow payments due, we determined the average monthly 

mortgage delinquency amount. We used that average and multiplied 

that amount by 24 months, essentially the beginning of the COVID-19 

pandemic through present. This gave us our $30,000 aggregate 

amount.

Eligibility

• Your application states that reinstatement of delinquent utility fees will not 

be an eligible assistance type. Can you summarize any community 

feedback or data on which you have based this decision?

Answer: With the finite amount of money to be received and the 

preliminary data provided, we are prioritizing homeowners who are 

behind in their mortgages and those who need help with future 

payments rather than budgeting for utility assistance. It is anticipated 

that the current utility assistance structure in Nebraska, with our 

support and advocacy, can handle utility costs. NIFA has built 

partnerships with Nebraska utility providers throughout our 

experience with the Emergency Rental Assistance program including 

sending weekly utility reports to the four largest providers with 

applicants who have been approved for payment. This method of 

reporting was essential to prevent unnecessary utility shut offs. NIFA 

relies on utility assistance from LIHEAP for households' income does 

not exceed the greater of 150 percent of the federal poverty guideline 

or 60 percent of the state median income level. The Nebraska 

Community Collaborative structure across the state can help fill in the 

gaps for homeowners needing utility assistance.

The Department of Economic Development contracted with the 

University of Nebraska Lincoln Center on Children, Families, and the 

Law to administer the Community Development Block Grant 

Coronavirus dollars for homeowners. This is being provided to the 
5

CDBG non-entitlement rural communities in the Balance of State 

Continuum of Care in Nebraska. DED is seeking approval from the HUD 

Field Office to utilize these dollars to pay for utilities. Between LIHEAP, 

the Community Collaboratives, and efforts with DED, we anticipate that 

utility needs will be met; however, we will consider expanding our 

services to include utility payments based on experience with NHAF 

homeowners. 

• Please provide additional information on the process by which a 

homeowner may receive both reinstatement and monthly housing 

payment assistance. Will reinstatement assistance be applied before the 

housing payment assistance or after?

Answer: The HAF program will apply funds to reinstate the delinquent 

loan before a homeowner can qualify for monthly payment 

assistance.

Outreach

• No questions

Prioritization

• Please describe your marketing and outreach strategy to SDI communities.

Answer: NIFA has strong collaborative partnerships with the State 

Human Services industry. These partnerships have grown stronger 

throughout our work helping coordinate the State Emergency Rental 

Assistance Program. We work across several divisions at the 

Department of Health and Human Services including the Division of 

Children and Family Services which oversees the Nebraska Homeless 

Assistance Program (NHAP), HUD Emergency Solutions Grant (ESG), Low 

Income Housing Energy Assistance (LIHEAP), and Social Security 

Disability Outreach Access and Recovery (SOAR). We are also involved 

with the Division of Behavioral Health, Division of Developmental 

Disabilities and Division of Medicaid. These divisions provide the overall 

structure of resources throughout Nebraska to socially disadvantaged 

and cost burdened renter and owner households. We have established 

a weekly steering committee for ERA that will add NHAF to the agenda. 

We participate in other weekly and monthly zoom meetings with these 

partners by providing outreach, marketing, engagement, collaboration, 

and problem solving to fill gaps and assure that providers and their 

clientele are being served. These meetings include the three Homeless 
6

Prevention Continuums of Care across Nebraska, and the Nebraska 

Children and Families Community Collaborative Central Navigator 

agencies. 

We are also closely engaged with the Nebraska Emergency 

Management Agency’s efforts and weekly meeting cycles. NEMA 

coordinates the boots on the ground flood and disaster recovery 

support network and the Nebraska chapter of the Voluntary 

Organizations Active in Disaster (VOAD). NEMA and VOAD worked 

throughout Nebraska after the 2019 floods and have since 

doubled/tripled their efforts to renters and homeowners affected by 

the pandemic. 

Our targeted market strategies will include focusing on counties that 

identified as areas with the most needs. Earned and paid media tactics 

including social media and billboards will be targeted to areas 

identified as socially disadvantaged. We will also work within the 

human services system mentioned about to disseminate the word 

through social graphics, flyers, and handouts on a local level.

• Your application states a target goal that 20% of homeowners receiving 

mortgage payment and reinstatement assistance, as well as 40% of 

homeowners receiving assistance on other property charges will be Socially 

Disadvantaged Individuals (SDIs). Please provide additional information on 

how this target will be met.

Answer: Our application reviewers will prioritize applications where the 

homeowner lives in a high-minority census tract. We will also use the 

CDC’s Social Vulnerability Index to identify areas of that have a higher 

vulnerability score in housing and transportation. We will coordinate 

and meet regularly with our partners identified above: the Department 

of Health and Human Services including the Division of Children and 

Family Services Homeless Prevention, the Continuums of Care across 

Nebraska, and the Nebraska Children and Families Community 

Collaborative Central Navigator agencies. Our established partnership 

with these agencies will ensure that we are reaching socially 

disadvantaged populations and receiving referrals to access assistance. 

We will evaluate our progress weekly toward meeting this goal to 

determine if we need to increase or adjust our community outreach 

and marketing efforts as also outlined above.
7

Performance Goals

• Please explain how you intend to communicate your progress towards 

performance to the public.

Answer: We plan to create a public-facing dashboard that will provide 

information about program progress. We also have Community 

Engagement staff that will present information about the HAF program 

and its progress to community groups and through NIFA’s educational 

webinars. We will also communicate progress during our weekly steering 

meeting with other resource providers.

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

the success of your program.

Answer:

a) Number of households applying for the program in relation 

to known household delinquencies by location

b) Percentage of funds targeted to households at or below 100% 

AMI.

c) Percentage of funds received by socially disadvantaged 

homeowners.

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

gender, etc.

Answer: Our intention is to collect data by every metric available and 

disaggregate by determined socially disadvantaged metrics first.

• Please consider including as an additional metric the number of 

homeowners assisted/foreclosures prevented solely through counseling or 

legal services without payment of HAF funds to resolve the homeowner’s 

defaults or delinquencies.

Answer: The HAF application process will include a tracking and 

reporting function that will monitor the progression and 

final outcomes of homeowners referred to a counseling agency or 

legal aid services. The counseling agencies are required to provide 

final reports when cases are resolved or closed.
8

Readiness

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

readiness, including staffing, contractors, etc.

Answer: 

a) HAF has hired a Program Manager and is still in process of hiring 

one additional compliance staff internally.

b) Software platform (Counselor Direct) is in the implementation 

phase and in testing. NIFA anticipates the platform will be ready 

by the end of December.

c) Call center has been finalized and is onboarding staff and will 

begin training on January 3, 2022.

d) Contracts are in process for auditing firm, Experian, Legal Aid and 

Housing Counselors

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

will you be ready to launch following approval?

Answer: We are confident and ready for any launch date. Our 

application platform is on target for receiving approval soon as well as 

all training material needed. Additionally, we have worked with 

Nelnet, our call center servicing center, who is also be prepared for the 

program to be launched.

• Please provide updated information about your progress in spending the 

initial 10% payment from your jurisdiction’s full allocation and the status of 

any pilot assistance already offered or made available to homeowners.

Answer: The State has contracted with several vendors for items such 

as data analysis on existing mortgages, an application portal to handle 

applications, contact center agents, auditing and accounting, and additional 

program staff to handle the additional responsibilities associated with the 

program. 

A pilot has not been launched with the structure of the program 
9

recently being established. There is also difficulty in designating who would 

qualify to be “first in line”. Marketing efforts are also being undertaken to 

ensure messaging is provided surrounding the launch date of the program 

to ensure the State is assessing need in an equitable process.

Budget

• Your budget includes $600,000 for assistance on payments related to down 

payment assistance loans, but there is no mention of this assistance in your 

term sheets. Additionally, there is a discrepancy of $600,000 between the 

budgeted amount for the Payment Assistance program in HAF plan versus 

the term sheets. Is payment assistance for down payment assistance loans 

a sub-component of the Payment Assistance program, and if so, can you 

provide more details on the criteria and process for assistance? Please 

update your budget, ifnecessary.

Answer: The $600,000 is to be included in the Payment Assistance 

Program ($5.5 million plus $600,000 equals the total amount of $6.1 

million for the Payment Assistance Program). Payments on existing 

amortizing second mortgages provided by a non-profit or government 

entity can be made for a period up to 6 months or until the maximum 

amount of assistance is reached. The applicant’s income will be 

recertified every 3 months to determine continued eligibility.