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HAFP-0262- State of Delaware 

Treasury Feedback for Resubmission of Plan 

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

Completeness

• No questions 

Homeowner Needs and Community Engagement

Data 

• No questions 

Community Engagement and Public Participation

• Please provide an update indicating any public comments you have received since you 

submitted your HAF Plan, from which organization you received any such comment, and 

whether you have responded to the comments. 

• No public comment has been received since Delaware submitted its HAF plan on 

March 11, 2022. 

Program Design 

• 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)? 

• We will address this based on scheduled foreclosure date and delinquency period (i.e. a 

tiered structure based on 120-day+, 90 day+, 60-day+). We will expedite process and prioritize 

anyone facing imminent foreclosure. Our application intake portal through Yardi will be 

configured to fast track application review based on these criteria.

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

homeowners in evaluating loss mitigation options available for their mortgage. Your description 

should include: 

DSHA is not mandating Housing Counseling in an effort to avoid any barrier to application into 

the program. However, we will be partnering with HUD-approved housing counseling agencies 

to help with application intake and submission processes and to assist homeowners who cannot 

participate in the program. Additionally, all participants in the program will be provided with 
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information regarding housing counseling providers and services for any ongoing support or 

assistance they may need. Similar partnerships with legal aid services will be established. 

Homeowners that cannot participate in the program will be connected with these services to 

continue exploring loss-mitigation efforts. 

We will include information about these services in all communication and advertisements and 

encourage seeking out supportive services as part of the HAF process.

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

services early in the process.

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

homeowners’ efforts at engaging in loss mitigation.

• 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?

Mortgage modification with state contribution will be available to all applicants. Collaboration 

with the servicer throughout the application review and reinstatement process or modification 

process will prevent duplication of relief options. Collaboration with the servicer for a 

modification program in unsustainable situations will ensure the HAF funds are used to create 

an ongoing sustainable 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 monthly payment? 

DSHA’s Fresh Start Mortgage Grant is designed to offer a one-time payment on behalf of a 

qualified homeowner to pay delinquent mortgage arrears and/or to facilitate mortgage 

modification (such as a principal curtailment or rate reduction) to right-size future mortgage 

payments to levels affordable to the homeowner. The following parameters will be utilized to 

determine the assistance provided:

• Applicants with a 31% DTI or less will be a straight reinstatement.

• Applicants between 31.01% - 45% DTI can opt into a modification agreement, otherwise 

straight reinstatement will be pursued.

• Applicants in excess of 45% DTI will be required to pursue a modification agreement.

• Applicant in excess of 80% DTI or with no income will be referred to a HUD approved 

Housing Counseling Agency and/or legal services to determine the best course of action to 

assist the applicant.

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

homeowners that HAF will serve?
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No. DSHA’s HAF plan does not cover utilities other than water and sewer. 

• Your program 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. Will 

this cap be sufficient in areas with higher housing costs? 

DSHA is offering two tracks – one that focuses on property charges up to $10,000 and one that 

focuses on mortgage reinstatement/modification up to $30,0000. Applicants meeting the stated 

terms for each track are eligible to apply for assistance through both tracks for a maximum 

assistance of up to $40,000. These caps are based on historical data from previous DSHA 

foreclosure prevention programs. If, during the course of the program, we determine this 

amount is insufficient, we will adjust accordingly. 

• Your HAF plan indicates that payment assistance for down payment loans will be provided, but 

your budget and term sheet make no mention of this program component. Will Delaware’s HAF 

program provide this type of assistance? 

No, we will not offer assistance for down payment loans. We will update our submission 

accordingly.

• Your HAF plan indicates that mortgage payment assistance will be provided but does not indicate 

the traditional form of mortgage payment assistance programs; monthly (forward) mortgage 

payment assistance, will be allowable. Can you clarify whether monthly payment assistance will 

be offered? 

Our plan contemplates bringing arrearages current and modifying existing terms to ensure longterm affordability for the applicant (see below for detail). We do not plan to make ongoing P&I 

payments as we do not feel that is long-term sustainable. 

DSHA’s Fresh Start Mortgage Grant is designed to offer a one-time payment on behalf of a 

qualified homeowner to pay delinquent mortgage arrears and/or to facilitate mortgage 

modification (such as a principal curtailment or rate reduction) to right-size future mortgage 

payments to levels affordable to the homeowner. The following parameters will be utilized to 

determine the assistance provided:

• Applicants with a 31% DTI or less will be a straight reinstatement.

• Applicants between 31.01% - 45% DTI can opt into a modification agreement, otherwise 

straight reinstatement will be pursued.

• Applicants in excess of 45% DTI will be required to pursue a modification agreement.

• Applicant in excess of 80% DTI or with no income will be referred to a HUD approved 

Housing Counseling Agency and/or legal services to determine the best course of action to 

assist the applicant.

• Your HAF plan indicates that mortgage principal reduction will be offered but provides few details 

on the eligibility requirements of this program. Please provide additional information on program 

eligibility. 

DSHA’s Fresh Start Mortgage Grant is designed to offer a one-time payment on behalf of a 

qualified homeowner to pay delinquent mortgage arrears and/or to facilitate mortgage 
5/31/22

modification (such as a principal curtailment or rate reduction) to right-size future mortgage 

payments to levels affordable to the homeowner. The following parameters will be utilized to 

determine the assistance provided:

• Applicants with a 31% DTI or less will be a straight reinstatement.

• Applicants between 31.01% - 45% DTI can opt into a modification agreement, otherwise 

straight reinstatement will be pursued.

• Applicants in excess of 45% DTI will be required to pursue a modification agreement.

• Applicant in excess of 80% DTI or with no income will be referred to a HUD approved 

Housing Counseling Agency and/or legal services to determine the best course of action to 

assist the applicant.

Eligibility 

• Your HAF plan indicates that self-attestations will be acceptable in lieu of income documentation 

but does not specify the fact-based proxy that will be utilized to make final determinations. Please 

provide additional information on how Delaware will determine income eligibility.

Action item: on UST portal, choose “no” for income proxy.

We do not have a fact-based proxy (based on certain assistance, QCT, etc.), therefore we will 

require supporting documentation. As reasonably necessary to accommodate extenuating 

circumstances, such as disabilities, practical challenges related to the pandemic, or a lack of 

technological access by homeowners, we will accept a self-attestation in place of 3rd party 

verification as part of the initial application, but will require 3rd party verification documents for 

approval. See attached DE-MRP Income Eligibility Documentation for additional details.

• Your HAF term sheets do not specify what types of documentation will be required to determine 

eligibility. Please provide additional information on the types of documents that applicants will 

be required to provide.

Please see attached DE-MRP Eligibility Requirements which outlines identity documentation, 

property verification documentation, and Third-Party Authorization. The DE-MRP Income 

Eligibility outlines required documentation for income verification. Our intake portal requires the 

applicant to select their qualifying event of hardship (see attached DE-MRP Hardship Attestation 

Form for list) and the Third-Party Authorization includes language to certify the accuracy of the 

application, including the hardship event.

Outreach 

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

limited English proficiency. 
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• Translation/Assistance Services. Assistance and translation services will be available for 

homeowners with limited English proficiency access.

• Community Outreach: Leverage community organizations, partnerships, and leaders in 

communities of color (i.e. Hispanic/Latino-focused, Haitian Creole-focused, others as identified). 

We will collaborate to create regular mortgage relief education events, hold listening sessions 

and use their distribution channels to share our materials.

• "Mortgage Help Sessions." Schedule hours held at targeted locations in specific 

communities, which will have a DSHA or an educated community representative physically 

present to facilitate walk-ins or appointments with residents who require Mortgage Relief.

• Community Publications: Place re-occurring ads and advertorials in publications that 

serve homeowners with limited English proficiency access (i.e. Hispanic/Latino-focused, Haitian 

Creole-focused, others as identified).

• Radio & Podcasts: Place re-occurring ads on our two Spanish-only radio stations, and 

hold Q&A interviews on those stations or podcasts with a Spanish-speaking DSHA 

representative. Will accommodate other language request as they arise. 

• Traditional and Digital Marketing communications strategies. Create multiple print 

collateral, from posters designed for retail or in-community placement to targeted direct-mail 

and leave-behind flyers.

• Outdoor: Deploy statewide advertising featured on public transportation that travels 

statewide (i.e., buses/bus shelters. ads will be bi-lingual. Bus shelters advertising will have more 

frequency in communities where English proficiency access is limited). 

• SMS Messaging: Use SMS in different languages (i.e. Hispanic/Latino-focused, Haitian 

Creole-focused, others as identified) to create two-way engagement and education to drive 

enrollment into the Mortgage Relief Program.

• Learnings from Emergency Rental Assistance Marketing Rollout. Delaware's ERA 

program, DEHAP, allowed the agency to refine its marketing strategies and build an outreach 

network that Delaware's Mortgage Relief Program can refer to or adjust while engaging 

homeowners with limited English proficiency access.

•

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

• Data. The agency will utilize mortgage and census data to identify specific high-need areas in 

our state. Data and learnings collected from the ERA marketing plan (i.e., digital analytics) will 

also be reviewed. This information will guide the agency in its targeted outreach efforts. 

• Partnerships. DSHA has an existing foreclosure prevention partnership with the Delaware 

Department of Justice (DOJ) dating back to the 2012 financial crisis. The DOJ operates the Office 
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of Foreclosure Prevention and Financial protection, which focuses on homeowner support and 

servicer accountability. Over the years, other relationships with the Delaware Court system and 

other community-based organizations have emerged. DSHA will leverage this existing 

infrastructure to reach new and already engaged Delawareans.

• Representation. All collateral will take into consideration and reflect cultural norms, values, and 

ethics. 

Prioritization 

• Please describe how your program will define Socially Disadvantaged Individuals, as well as your 

marketing and outreach strategy to SDI communities. 

• Once defined internally, a marketing and outreach strategy can be created

• Delaware will utilize Treasury’s definition and description of Social Disadvantaged Individuals. 

o Socially disadvantaged individuals 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 3 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 Land, 

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.

• Delaware will implement the following the marketing strategies to reach SDI communities: 

• Partnerships. Over the years, DSHA has developed existing partnerships with various 

community leaders and organizations that serve SDI communities. The agency will leverage 

this existing infrastructure to reach new and already engaged Delawareans that meet the 

definition cited above. We will collaborate to create regular mortgage relief education 

events, hold listening sessions and use their distribution channels to share our materials.

• Data. The agency will utilize mortgage and census data to identify specific high-need areas 

in our state. Data and learnings collected from the ERA marketing plan (i.e., digital analytics) 

will also be reviewed. This information will guide the agency in its targeted outreach efforts. 

• "Mortgage Help Sessions." Schedule hours held at targeted locations in specific 

communities, which will have a DSHA or an educated community representative physically 
5/31/22

present to facilitate walk-ins or appointments with residents who require Mortgage Relief.

• Traditional and Digital Marketing communications strategies. Create multiple print 

collateral, from posters designed for retail or in-community placement to targeted directmail and leave-behind flyers.

• Outdoor: Deploy statewide advertising featured on public transportation that travels 

statewide (i.e., buses/bus shelters. ads will be bi-lingual. Bus shelters advertising will have 

more frequency in communities where English proficiency access is limited).

• SMS Messaging: Use SMS in different languages (i.e. Hispanic/Latino-focused, Haitian 

Creole-focused, others as identified) to create two-way engagement and education to drive 

enrollment into the Mortgage Relief Program.

Performance Goals 

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

• Website. Create and update monthly a data dashboard webpage, which will include key 

metrics that communicate progress. The agency already has access to a platform to utilize. 

• Social Media. Create and publish monthly update posts that communicate progress and 

success stories, encourage participation, and drive constituents to the webpage mentioned 

above. 

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

program. 

Success will be measured through applications processed, applications funded, housing 

sustainability preserved (through funding and/ or loss mitigation with further assistance of 

housing counseling and/ or legal services.) 

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

We will collect HMDA data, but the focus of our performance goals will be the number of 

households served.

• 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. 

Readiness 

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

staffing, contractors, etc.
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DSHA has a signed contract with Yardi for the application intake portal and call center for 

application submission support. DSHA has a signed contract with Witt O’Briens for the case 

management and file review. DSHA is actively hiring additional internal staff to work with our 

outside partner in support of the program.

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

launch following approval? 

We are on track to meet our pilot launch date of May 16, 2022 that will focus on our Master 

Servicer portfolio. Our full program will launch May 31, 2022.

• 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.