HAFP-0080-Missouri

Responses to Treasury Feedback for Resubmission of Plan

Completeness

Your plan lists Jennifer Schmidt as the Authorized Official, while the original application for 

HAF payments was signed by Luke Holtschneider. 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

Homeowner Needs and Community Engagement

Data

Please explain how the plan targeting and outreach reflect the data referenced in your plan.

As identified in the Missouri Needs Assessment, Missouri encompasses almost a quarter of a million 

homeowners under the 100% US median income threshold and even more when considering that 17 of 

Missouri's counties have higher AMIs than the US median income. Highly represented within these 

households are socially disadvantaged individuals. The vulnerability of these populations was increased 

even more so by the pandemic, making it imperative that the Missouri Housing Development 

Commission (MHDC) have a clear strategy for reaching this need with the State Assistance for Housing 

Relief (SAFHR) for Homeowners program, created to administer the Missouri allocation of the 

Homeowner Assistance Fund (HAF). 

1. Income Targeting

MHDC is committed to working in coordination with national and localized servicers to target portfolios 

made up of lower income homeowners. Based on the Needs Assessment, MHDC will utilize geographic 

targeting strategies to provide print and digital marketing materials, specifically in areas identified to 

have high levels of low income households with high delinquency rates and/or high forbearance rates. 

MHDC will also engage and educate community partners to further extend the reach of information. 

These community partners include Community Action Agencies, United Way 2-1-1, non-profit networks, 

childcare agencies, and other banks and institutions not solely limited to mortgage servicers. 

2. Targeting Socially Disadvantaged Individuals (SDIs)

Similar to strategies in targeting lower income homeowners, MHDC will utilize a variety of opportunities 

to provide targeted communication and education around SAFHR for Homeowners for socially 

disadvantaged individuals. The Needs Assessment will be utilized to identify areas of greatest need of 

assistance. MHDC has begun outreach to partner with organizations and entities that specifically 

connect with some of the disadvantaged populations identified such as the Black Chamber of 

Commerce, Hispanic Chamber of Commerce, American Indian Council, Metro St. Louis Equal Housing 
Opportunity Council, Empower Missouri, and more. As with income targeting, MHDC will utilize 

geographic targeting strategies here as well to provide print and digital marketing materials specifically 

to those counties identified as poverty-persistent and areas with majority-minority census tracts. 

3. Statewide Targeting Partners 

To effectively reach all targeted groups throughout the state, MHDC has engaged with a marketing firm 

to provide messages and run an advertising campaign that will align with all geographic and 

demographic methodology. In addition, MHDC is actively working with servicers to provide materials 

and assistance to reach out to delinquent portfolios aligning with targeted groups. MHDC is partnering 

with United Way 2-1-1 to extend the reach of information and preparation to homeowners statewide 

that may not have any other pathway to homeowner assistance resources. 

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.

To best serve the state of Missouri and homeowners in need, public participation and community 

engagement in the development of this plan have been critical. The first step of engagement was to host 

informational webinars and feedback sessions for both housing counseling agencies and mortgage 

lenders and servicers represented in Missouri to learn from those on the front line regarding 

homeowner needs and the most significant opportunities to resolve delinquencies and prevent 

foreclosures. The resounding sentiment regarding most impactful program design was mortgage 

reinstatement. 

The next step of MHDC was to assemble an advisory committee with representation from Mortgage 

Bankers Association of Missouri, entitlement communities, and housing counseling agencies. This 

committee met on a weekly basis since the beginning of May to strategize solutions in outreach and 

marketing, engagement of socially disadvantaged individuals, servicer coordination and more. MHDC 

specifically reached out to multiple entitlement communities to consult with them regarding the needs 

of eligible homeowners in Missouri and to identify strategic outreach efforts. 

The final step of engagement was outreach to business, community and faith groups representing 

socially disadvantaged individuals. Connection through the establishments that have built trust with 

those MHDC seeks to serve will allow for the most effective deployment of the SAFHR for Homeowners 

program. 

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.
The Missouri Housing Development Commission has not received any substantive comments since 

submitting the HAF Plan outside of inquiries regarding the launch date of direct assistance for Missouri 

homeowners. 

Ongoing Assessment of Homeowner Need

Please explain how the program will address changes in homeowner needs in the coming 

years.

The Missouri Housing Development Commission has begun with a focus on reinstatement as a broad 

scale approach to remedy Missouri homeowner delinquency. As that program progresses, MHDC will 

assess homeowner denial reasons through the application portal, continue to engage with stakeholders 

through an established advisory committee, analyze delinquency data for the state, and process 

feedback from the engaged housing counseling and legal aid entities funded through Mortgage 

Assistance Counseling. This data and detail will allow MHDC to assess changes in homeowner needs to 

determine the necessity of additions or adjustments to program design elements. 

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)?

Upon program launch, Missouri’s application portal will request each homeowner applicant to attest 

whether or not they are facing foreclosure, allowing MHDC to quickly identify the immediate threat, 

validate by requesting a copy of the foreclosure notice, and expedite the process for the homeowner at 

risk. Due to the nature of the reinstatement design, MHDC will not be assessing other threats such as 

HOA liens, tax delinquencies, or utility shut offs but will provide advertising and referrals to HUDcertified housing counseling agencies to work with homeowners on action plans, budgeting, and 

additional resources. 

Recognizing the immediacy of homeowner needs across the state, MHDC has launched the Mortgage 

Assistance Counseling (MAC) program to support housing counseling and legal services ahead of direct 

assistance launch to help homeowners evaluate available options for mitigating loss and avoiding 

foreclosure as they navigate the threat of housing instability.

Please confirm your exclusion of reverse mortgages and contracts for deed and explain what

steps you have taken to assess the needs of homeowners with reverse mortgages and 

contracts for deed. Please summarize any community feedback or data on which you have 

based this decision.
Due to the need to address statewide delinquency, the Missouri Housing Development Commission has 

begun with a focus on reinstatement as a broad scale approach. This determination was made in an 

effort to address the highest and largest need statewide, and was determined through community 

feedback. As that program progresses, MHDC will assess the need for possible program design additions 

or inclusions through the assessment of applicant denial reasons, stakeholder input, feedback from the 

network of engaged non-profit agencies, and the analysis of delinquency data. 

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:

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

services early in the process.

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

homeowners’ efforts at engaging in loss mitigation.

MHDC has launched a Mortgage Assistance Counseling (MAC) program to provide funding to HUDCertified housing counseling agencies and legal aid entities across Missouri to walk homeowners in need 

through loss mitigation efforts before Homeowner Assistance Fund dollars are available for direct 

assistance. Upon Treasury approval, MHDC will launch the direct assistance program for homeowners, 

while remaining engaged with MAC agencies across the state to provide housing counseling, legal 

services, and application support. MHDC will communicate through both a public-facing and promoted 

website, www.mohousingresources.com, the landing page for the application portal, and through prescreening questions for homeowners to receive referrals to HUD-certified housing counseling agencies.

These MAC agency services will also be promoted as a part of the overall Missouri homeowner 

assistance marketing campaign. 

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?

With loss mitigation, MHDC recognizes that the experts are the servicers and the housing counseling 

agencies that engage with homeowners to assist. MHDC will consistently guide homeowners through 

advertising, communication, and built-in referrals to these partners that can best advise the homeowner

of the options that will best serve them. MHDC believes that it is the role of the HAF grantee to provide 

and support connection to those industry experts who hold the loss mitigation options. 

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?
MHDC’s program is designed to open up and provide statewide assistance quickly by first offering 

reinstatement services. The direct assistance program, along with the Mortgage Assistance Counseling 

(MAC) program, which utilizes HUD Housing Counseling agencies, will effectively allow homeowners to 

be able to quickly avoid foreclosure, and gain access to counseling services to evaluate the best future 

options. As the program progresses MHDC will continue to evaluate needs across the state, and adjust 

the program to add additional services as necessary. MHDC’s assistance program, and the work done 

with outside community partners is designed to move quickly and adapt over time in order to most 

effectively and efficiently assist homeowners in attaining housing stability.

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

homeowners that HAF will serve?

MHDC recognizes the upward trend of home energy costs that will impact Missouri residents this 

winter. While MHDC provides the opportunity for reinstatement to delinquent homeowners in the 

state, the agency will look to partner with other services and assistance programs across the state to 

address these needs. 

Eligibility

Please provide the rationale for not using a fact-specific proxy as one method for establishing

eligibility under your plan, including how you determined that without such a proxy, your

program can avoid unnecessary barriers to participation by eligible homeowners.

The Missouri Housing Development Commission has been intentional in its initial program design so as 

to offer the most effective and needed service first to prevent as many foreclosures as possible. The 

program design allows MHDC to continue to assess any potential barriers presented through the 

administration of this program and adapt over time. 

Outreach

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

limited English proficiency, including those that are not Spanish speakers.

In an effort to prevent as many foreclosures as possible, the Missouri Housing Development Commission 

has designed its program to go into operation as quickly as possible, and to ensure those services cover 

as much of Missouri’s population as possible. The overwhelming majority of the population in Missouri 

speak either English or Spanish. Print and digital marketing is currently being developed to be made 

available in both English and Spanish. However, MHDC will ensure that other languages are offered, and 

that all eligible homeowners in need of assistance may receive it. For additional languages represented 

in Missouri, MHDC has already begun to engage a network of non-profits for the Mortgage Assistance 

Counseling program to expand its ability to reach and serve those homeowners in need, despite any 

language barrier. In addition, MHDC has ensured that all of the landing pages on the application portal 
explaining the program, required documents, frequently asked questions, and more have a plug-in that 

provides translation into over 100 languages. 

Please explain how the program will provide culturally relevant marketing.

MHDC is working with a broad number of community partners to provide culturally relevant outreach 

through entities that have established community relationships across the state in rural, suburban, and 

urban communities. In addition to this network of agency partners, MHDC is also engaged with a 

marketing firm that developed the state’s marketing of ERA. Further marketing efforts will build on 

those existing efforst for both combined marketing and advertising as well as homeowner-specific 

advertising efforts. 

Prioritization

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

your program prioritize Socially Disadvantaged Individuals?

MHDC has worked closely with a contracted software solutions company for the ability to identify each

homeowner applicant’s demographic data to determine and therefore prioritize majority-minority

census tracts, poverty persistent counties, homeowner applicants with limited English proficiency and 

homeowner applicants that are members of a group that has been subjected to racial or ethnic 

prejudice or cultural bias within American society. 

Performance Goals

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

public.

MHDC has established a public-facing dashboard on www.mohousingresources.com for other COVID 

relief performance metrics and will incorporate HAF performance and progress metrics. 

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

program.

The three metrics which will serve as best indicators of the success of Missouri’s program are: 

1. Percent of targeted populations served (at or below 100% AMI or SDIs)

2. Number of foreclosures prevented

3. Geographic distribution of funds

Please indicate whether you intend to disaggregate metrics by income, race, gender, etc.
MHDC does not intend to disaggregate metrics on its public-facing dashboard by income, race, gender, 

etc. but does have the ability to report on these disaggregated metrics, if necessary. 

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.

MHDC is open to all possibilities and will continue to assess this over time. 

Readiness

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

including staffing, contractors, etc.

Staffing

MHDC will utilize the full organizational financial department and executive staff to aid in the 

sustainability of the program. Additionally, MHDC has key staff that are actively working on program 

development with plans to increase those positions to meet additional needs as they arise. The current 

staffing structure includes: 

 Director of Operations

 Division Director

 Department Manager

 Departmental Supervisor(s)

 Program Administrators

 Compliance staff

 Organization data and reporting staff

 Departmental data and reporting staff

 Departmental financial staff

Contractors

MHDC has contracted with Customer Direct for contact center services and is currently establishing call 

scripts and providing training on application software for general application support. 

MHDC has contracted with AmeriNat to conduct all application processing and underwriting. Together 

MHDC and AmeriNat have established review and underwriting checklists and are conducting training 

on application software for clear understanding of use for all processing. 

MHDC has contracted with HOTB Software Solutions to utilize their Counselor Direct software. The

application portal has been crafted to all Missouri specific criteria and information in preparation of 

homeowners interacting with it. Both MHDC and the software company have prepared to launch the 

live application portal on January 3rd, 2022. 
To ensure effective program compliance, MHDC has also engaged with an outside legal firm for the 

duration of this program. MHDC engages annually with an external auditing form to conduct annual 

program audits. Lastly, MHDC has engaged with an external consulting firm to assist program staff and 

internal compliance department in the development of policies, procedures, and internal controls. 

Servicers

MHDC has conducted outreach to formally engage servicers through a servicer participation agreement 

and packet. This outreach went out to over 300 servicers. MHDC will utilize the Common Data File as the 

key conduit in program delivery for mortgage servicer coordination. MHDC is working with engaged 

servicers to set up

Housing Counseling and Legal Aid Entities

MHDC has established the Mortgage Assistance Counseling program for HUD-Certified Housing 

Counseling agencies and Legal Aid entities to provide supportive services to struggling homeowners 

leading up to and during the SAFHR for Homeowners program. These entities will be used as an

administrative entry point for many program participants to assist in the effective delivery of SAFHR for 

Homeowners. MHDC recognizes that these counselors have the experience and resources necessary to 

navigate loss mitigation processes and other options that can lead to permanent housing affordability.

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

to launch following approval?

MHDC is prepared to launch as early as Monday, January 3rd, 2022, following approval. 

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.

MHDC has utilized a portion of the initial 10% payment in preparation of program lunch, engaging the 

necessary vendors, creating marketing materials, and launching the Mortgage Assistance Counseling 

(MAC) program for HUD-certified housing counseling agencies and legal aid entities. MAC agencies have 

already begun to engage homeowners to support them in the navigation of loss mitigation options and 

other housing stability planning. 

MHDC has not extended any pilot assistance in the form of direct assistance to homeowners. 

Budget

Your plan indicates that mortgage reinstatement is the only program design element with a

budget allocation. Please confirm.

MHDC confirms this as the only design element with a budget allocation.