HAFP-0086-Ohio

Treasury Feedback for Resubmission of Plan

Completeness

The participant’s response(s) to the following questions was/were either incomplete or unresponsive:

• None

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

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.

Ohio’s HAF plan was developed after extensive consultation with affordable housing 

advocates and stakeholders. Shortly after receiving initial guidance from the U.S. Department 

of the Treasury, OHFA began holding informal discussions with interested parties about the 

top-level goals and principles OHFA should consider in developing an effective suite of 

programs to help homeowners who have experienced financial hardship as a result of the 

coronavirus pandemic.

Early in the plan development process, OHFA convened a virtual meeting of about thirty 

advocates and stakeholders from around the state, including representatives from Legal Aid 

organizations, community development corporations, homeless advocacy organizations, 

mortgage lenders and servicers, and federal government agencies. This forum gave OHFA the 

opportunity to benefit from the advice of those representing a wide range of perspectives and 

experiences. There were several themes that had strong support from most, if not all, of the 

participants. Among these are streamlining distribution and eligibility requirements; focusing 

on internal operations and efficiencies; ensuring data integrity; creating durable, productive 

support networks; and leveraging relationships with leaders who are trusted in the 

communities that are being targeted. Attendees strongly encouraged OHFA to focus efforts 

first on programs designed to help homeowners retain their homes; programs like home 

repair and maintenance, while important and helpful, were deemed less critical, and there 

was general agreement that these types of programs should only be developed after the crisis 

of impending foreclosures was addressed.

OHFA was also able to draw on lessons learned from administering the Hardest Hit Fund (HHF) 

over the last decade. Of particular note, OHFA staff met with Stephanie Casey Pierce, who was 

instrumental in the development and administration of the HHF and who is now at the Ohio 

State University working on an evaluation of the HHF foreclosure prevention program. Having 

spent a decade designing, administering, and studying Ohio’s HHF program, she is an 
invaluable source of insight into aspects of the program that have proven to be effective as 

well as those that she would do differently if she had it to do over again.

On June 16, 2021, OHFA published a draft of this plan, invited written public input via a 

dedicated email address, and announced a public hearing, which was held virtually on June 

22, 2021, and attended by sixty-nine people. Much of the feedback was in the nature of 

questions about particular program details. Suggestions included reducing the cap on the 

amount of assistance any individual could receive; adding a minimum amount of time that 

someone receiving assistance must stay in the house without having to pay back at least a 

portion of the assistance because of concerns about undue enrichment; requiring those who 

receive assistance to also receive housing counseling (it should be noted that we have also 

received advice that we should not make receiving housing counseling an absolute 

requirement given that it could be a disincentive, and thus a barrier, to those who have found 

themselves experiencing a financial hardship through no fault of their own); providing funds 

to housing counseling agencies and legal aid providers; eliminating the restriction on receiving 

assistance for those who are in an active bankruptcy; and paying for expenses that were 

incurred and came due prior to January 21, 2020.

• 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.

OHFA has not held any additional public hearings on the plan nor has OHFA received any 

additional written comments on the draft plan. OHFA has had ongoing conversations with 

Housing Counseling Agencies and Legal Aid Service organizations about the operation of the 

pilot phase and data that is beginning to come in to inform potential program adjustments.

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.

While much of the data that is available predates the pandemic and is therefore of limited 

use, or is not granular enough to be particularly useful, there is a great deal of evidence that 

the most pressing needs facing Ohio’s homeowners are reinstatement of delinquent 

mortgages, assistance with future mortgages in order to help homeowners get back to a 

position of financial stability, and assistance with both delinquent and ongoing utility 

payments, property taxes, and homeowner-related fees. Since we began operating programs 

to address these needs in the pilot phase, the level of activity has confirmed the demand for 

this assistance.

• 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)?
Yes. OHFA has entered into subaward agreements with a number of community action 

agencies (and continues to have discussions with others about doing so) because the 

community action agencies are uniquely prepared in Ohio to evaluate precisely these types of 

threats to the housing stability of applicants.

Furthermore, OHFA is evaluating the risk of imminent foreclosure to homeowners who apply 

for Rescue Payment Assistance (RPA) and expediting the review of these applications to 

determine if RPA will prevent the foreclosure.

• 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:

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.

In the prequalification and application process, homeowners will provide the date their 

delinquencies began. If the homeowner is facing an imminent foreclosure and the Rescue 

Payment Assistance (RPA) program OHFA is administering would stop that foreclosure, OHFA 

will process that application and, if the applicant is determined to be eligible, OHFA will make 

the payment to the servicer. If, however, the RPA would not stop the foreclosure or the 

applicant is determined not to be eligible, OHFA will refer the applicant to housing 

counseling/legal services.

If the homeowner is not facing imminent foreclosure and their delinquency began prior to 

their hardship date, OHFA will refer the homeowner to housing counseling/legal services if the 

homeowner has not been through a loss mitigation process or if the homeowner has been 

through the loss mitigation process but it’s not current. If the housing counseling/legal 

services then recommends the HAF programs as the most appropriate assistance for the 

homeowner, OHFA will process the application and determine eligibility.

This process is best illustrated in the flow chart below.
• In situations where the HAF assistance includes or will be limited to payments for mortgage 

reinstatement, please explain whether and how your [sic] will assess whether a similar or more 

appropriate alternative loss mitigation option is available through the servicer.

Please see the prior answer and illustration. Additionally, we are requiring servicers to use the 

new Common Data File that includes eight (8) columns related to current COVID loss 

mitigation status.

• 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?

Please see the prior answer and illustration.

• 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?

If homeowners were delinquent on their mortgages prior to the onset of their coronavirus 

pandemic-related financial hardship, their mortgages were not sustainable before the 

pandemic, which made a bad situation worse. For these homeowners, as long as they are not 

facing imminent foreclosure that could be prevented by the speedy processing and approving 

of HAF funds, OHFA will refer them to housing counseling/legal services to determine the best 
approach to address the causes of their inability to make the mortgage payments.

If the coronavirus-related financial hardship took place before the delinquency began and 

thus is the direct cause of the delinquency, OHFA will process that application and, upon a 

determination of applicant eligibility, provide HAF fund assistance.

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

homeowners that HAF will serve?

Yes. That is why we have enlisted community action agencies to administer the Utility 

Assistance Plus program we have developed. Because they administer similar utility assistance 

programs, they are best able to determine the appropriate sources of assistance for applicants 

in a cost-effective and efficient way.

Eligibility

• No questions.

Outreach

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

limited English proficiency.

Ohio will undertake a two-tiered approach to target funds to homeowners living in counties 

with a high share of mortgage delinquencies and high unemployment rates: 1) purchase and 

earned media and 2) direct community outreach. 

Data and research will provide critical direction to the program’s marketing and 

communication plan. The number of delinquent loans will guide the communications team’s 

efforts to reach into targeted communities. Although every Ohio region will receive 

advertising about the program, areas with the highest need and the highest number of 

socially-disadvantaged individuals (SDIs) will receive a higher concentration, thereby 

increasing the likelihood that the program’s message will reach its target audiences and that 

those targeted audiences will apply for and receive assistance. 

Ohio’s marketing and advertising plan to target this cross section of homeowners includes 

traditional far-reaching media outreach, niche publications/broadcast advertising (e.g., 

Spanish-language newspapers), and the use of data-driven advertising methods. 

OHFA will employ traditional media outreach through earned media: press releases, media 

interviews, and news media stories. OHFA will launch the statewide campaign at a press 

event, offering local and statewide media a central location to ask questions, receive 

materials, and interact with the appropriate staff to get accurate information about the 

program. Media will help disseminate the program details across the state. 

OHFA will use outdoor and transit advertisements to highlight the program’s availability to a 

wide swath of Ohioans, focusing attention on the Ohio HAF 1-800-number and website, and 

encouraging those at-risk to call and visit the website. In addition, OHFA will use census tract 

data to focus some outdoor and transit advertisements on areas of greatest need. Outdoor 

ads and billboards can be particularly beneficial in some rural communities that don’t have 
consistent access to the internet. Trusted sources of information in SDI communities include 

niche print publications and/or broadcast outlets, in which OHFA will place ads and, when 

possible, editorial content. 

Share and like buttons, along with other social media tools, propel today’s word of mouth. 

OHFA intends to use digital media to its advantage by advertising via Google and Facebook. 

OHFA will do this both specifically focused on HAF programs and as part of larger media 

campaigns with vendors across the state, including print, radio, and television outlets. These 

vendors also offer opportunities to participate in interviews with local talent, furthering the 

goal of making as many Ohioans as possible aware that help is available. 

Data-driven tools like geo-targeting and geo-fencing send ads/information to persons who are 

within a certain radius or at certain locations. Ohio will request to target specific 

demographics using these options. Staff will use these tools in concert with data and the 

aforementioned census tracts. 

Other tools available for promoting the program include streaming radio, targeted email 

blasts to Ohioans that meet the criteria set forth in the guidelines, and targeted display ads. 

OHFA also regularly creates content, including a podcast and blog. Both tools will be used to 

showcase the program and discuss its benefits. The OHFA website will include a special 

section outlining program eligibility requirements and how Ohio homeowners can apply for 

assistance. OHFA’s website routinely sees more than 20,000 users each month, with more 

than 80,000 page views. OHFA anticipate that number increasing significantly when the 

program officially launches. 

OHFA will place a heavy emphasis on leveraging the expertise, relationships, and credibility of 

community-based organizations. OHFA anticipates engaging with these organizations to go 

door-to-door in neighborhoods with high concentrations of eligible homeowners who are atrisk of foreclosure, which will include saturating neighborhoods and communities that have 

significant populations of socially disadvantaged individuals. As we receive data about the 

homeowners who are applying for and receiving assistance, OHFA is prepared to adapt and 

redirect resources to areas that continue to be underserved. These community-based 

organizations can also help facilitate community meetings at which OHFA or other trusted 

partners present information about the HAF programs.

OHFA is working with the Governor’s Office of Faith-Based and Community Initiatives 

(GOFBCI) to engage the faith leaders around the state. OHFA has discussed attending and 

presenting at one of the GOFBCI’s “Ask the Experts” events to present information about the 

HAF plan and seek to enlist their support in disseminating information about it to their 

congregations.

Organizations and state government agencies that routinely communicate with Ohioans who 

may be income-eligible homeowners are important partners who also help inform those who 

might benefit from Ohio’s HAF programs. OHFA plans to develop informational inserts for 

inclusion in mail that these organizations send to their clients and customers. OHFA will 

likewise develop information that can be included in email communications.
In an effort to reach those individuals with limited English proficiency, OHFA has subscribed to 

a translation service which allows OHFA staff to communicate with individuals speaking 

languages other than English and assist them with filling out an application when necessary. 

Furthermore, OHFA has already begun translating fact sheets about the HAF programs in 

other languages (e.g., Arabic, Chinese, French, German, and Spanish) and is prepared to 

translate other documents as is determined necessary after consulting with community-based 

organizations who intimately aware of the needs of their neighborhoods; this includes 

exploring the feasibility of creating an informational version of the application as a PDF

document that we could translate into other languages. OHFA will be encouraging these 

community-based organizations to assist limited English proficiency individuals with the 

online application process as well.

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

Please see the prior answer.

Prioritization

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

your program prioritize Socially Disadvantaged Individuals?

We are prioritizing Socially Disadvantaged Individuals (SDIs) regardless of whether they are in 

households below or over the 100% AMI threshold. Based on the results of the Pilot Phase, we 

will prioritize those areas with high concentrations of SDIs that we identify as applying in 

disproportionately low levels. Please see the prior answer regarding Outreach for more 

details.

Performance Goals

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

public.

We will be producing quarterly Performance Reports that will track our progress on meeting 

our performance goals. These will be presented at OHFA’s Board Meetings, which are open to 

the public, and will be published on our website along with all of our other performance data. 

We will also be communicating extensively with the public about the availability of the 

programs that can assist them.

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

program.

The three metrics that will serve as the best indicators of the success of our program are:

o Total homeowners assisted financially 

o Percentage of homeowners assisted financially who are socially disadvantaged 

o Total homeowners receiving housing counseling or legal services, in lieu of OHFA 

financial assistance, after an OHFA referral 

• Please indicate whether you intend to disaggregate metrics by income, race, gender, etc.
Yes. We are already disaggregating the metrics by income, race/ethnicity, and gender.

• 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).

We plan to collect these data from our third party housing counseling and legal aid agencies.

To the extent that it is possible, this will include tracking whether homeowners receive loan 

modifications.

Readiness

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

staffing, contractors, etc.

We are ready and operating. We have hired nine (9) employees to administer the Rescue 

Payment Assistance and Mortgage Payment Assistance programs. We have entered into a 

contract with the Ohio Homeowner Assistance (OHA), the former fiduciary for the Hardest Hit 

Fund, to process payments to servicers, and payments are currently being made through 

them. We have entered into agreements with many of the servicers and continue to reach out 

to those that have not yet signed agreements. Our IT team has developed a prescreening and 

application web portal which is up and running. 

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

launch following approval?

Our program is not only prepared to launch upon approval, our base programs (i.e., Rescue 

Payment Assistance, Mortgage Payment Assistance, and Utilities Assistance Plus) are already 

up and running. We have been less aggressive than we will be once Treasury approves our 

plan because we do not want to ramp up, create an expectation among the public, and then 

run out of money and be unable to meet those expectations.

• 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.

Through the end of October 2021, we have spent or obligated approximately $14.6 million. 

This includes approximately $9.1 million in Rescue Payment Assistance and Mortgage 

Payment Assistance as well as approximately $4.9 million to community action agencies for 

Utility Assistance Plus assistance. Additionally, we recently moved $1.5 million from 

Administrative costs to the Mortgage Payment Assistance program because of the significant 

demand for this assistance.

Budget

• None.

Other

As with virtually every aspect of the programs OHFA is operating in the Pilot Phase, we intend 

to periodically evaluate the appropriateness of parameters that we have put in place. This 
includes, among other aspects, the size of the cap on the amount of assistance a homeowner 

may receive.