v.10/11/2021 Page 1 of 10

Oregon Housing and Community Services | 725 Summer St. NE Suite B, Salem, OR 97301-1266 | (503) 986-2000 | FAX (503) 986-2020 

Homeowner Assistance Fund 

Emergency Housing Team 

U.S. Treasury 

Dear U.S. Treasury HAF team, 

Please find below responses to your November 23, 2021 requests for additional information or 

clarification. If you have further questions related to this document or the Oregon HAF submission, please 

do not hesitate to email me at ryan.vandenbrink@hcs.oregon.gov or to phone me at 971-720-3775. 

Updated program terms with track changes will be uploaded to the portal. The HAF plan uploaded with 

the original submission has not been revised but can be upon request. Changes within the portal include: 

1. SDI targeting: added a sentence on a prioritization tool Oregon developed for use. 

2. Languages: added Chinese as a fifth chosen language. Please note in the pilot we were only able 

to offer English and Spanish. In addition, for the main program, we are working on an issue related 

to the online application portal. If it is not technologically or cost feasible to offer the online 

application in all five languages, we will continue to offer online and paper program materials and 

a paper application in all five languages. 

3. Pilot information was updated because our pilot opened to Phase 1 applicants on November 30, 

2021. 

4. Budget information was updated to request the full allocation. Our administrative requests should 

now be within the 15%. Budget allocations within the administrative estimates may change as 

program activities, contracts and grants are finalized. 

5. Our agency email addresses were change and updated in the portal. 

Thank you, 

Ryan Vanden Brink 

Assistant Director of Homeowner Assistance Programs 

*** 

Completeness 

 Your plan lists Ryan Vanden Brink as the Authorized Official, while the original application for 

HAF payments was signed by Caleb Yant. 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 

Oregon Housing and Community Services believes that multiple individuals are authorized 

officials for the rental assistance program. For HAF, the agency intends to request appointment 
Oregon HAF – U.S. Treasury Feedback Responses 

Page 2 of 10

Oregon Housing and Community Services | 725 Summer St. NE Suite B, Salem, OR 97301-1266 | (503) 986-2000 | FAX (503) 986-2020 

of Beth Brown and Ryan Vanden Brink as additional authorized officials for HAF. As requested, a 

submission request will be made to HAF@treasury.gov. 

Homeowner Needs and Community Engagement 

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

The agency completed its homeowner needs assessment based upon both quantitative and 

qualitative data listed in the HAF plan and portal application. The Oregon data and needs 

analysis was shared with stakeholders and the public and feedback was incorporated into the 

HAF plan, including the outreach and targeting sections, program design, and our more detailed 

outreach and communication strategies. For instance, the agency has provided pre-program 

initial foreclosure prevention information in presentations to BIPOC homeowners, including 

presentations in Spanish, based upon data that Black and Hispanic populations have a higher risk 

of foreclosure and displacement. The agency plans to continue this outreach and fund marketing 

and outreach by community-based organizations, including culturally-specific organizations and 

rural organizations. The data helped shape the agency’s outreach and communications plan as 

well as efforts to assist with direct outreach by trusted local partners. 

The agency is using the needs analysis and data to implement its outreach plan as well. For 

example, a prioritization tool was developed using various data sets related to the U.S. 

Treasury’s SDI definition and related data sets. The agency can use this data to target outreach 

to various zip codes in Oregon that are likely to be the most at-risk. The agency has 

operationalized its targeting of priority populations as well using program application priorities, 

so that populations identified as the most at-risk are prioritized during the application process. 

Community and Public Participation 

 Please describe any coordination you intend with Tribes and Tribal entities. 

The agency has contacted the Confederated Tribes of Oregon and convened two meetings with 

representatives of the Tribes to discuss HAF, coordination and planning, and general housing and 

capacity issues. Oregon plans to offer HAF assistance to Tribal members to leverage HAF funding 

for Tribes while taking steps to avoid duplication of benefits for the same time period or costs. 

Now that Oregon’s pilot program is open, the agency plans to engage Tribes again to discuss 

collaboration or coordination in marketing, intake assistance, fraud prevention, and fast-tracking 

tribal member applications where those members have already been approved under the same 

program eligibility requirements with the Tribes. 

These discussions will continue beyond HAF as Oregon and some Tribes expressed interest in 

coordinating other homeownership and foreclosure prevention opportunities. 

 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. 

After submission of Oregon’s HAF plan and program terms to the U.S. Treasury, copies of each 

were placed on the agency’s website. U.S. Treasury’s feedback and questions were also placed 
Oregon HAF – U.S. Treasury Feedback Responses 

Page 3 of 10

Oregon Housing and Community Services | 725 Summer St. NE Suite B, Salem, OR 97301-1266 | (503) 986-2000 | FAX (503) 986-2020 

on the agency’s website and emailed to several stakeholders for comment on four of the 

questions. The agency received the following public comments at its Housing Stability Council 

meeting update on December 3, 2021: 

1. Housing Alliance (a coalition of homeownership advocates): Written comments expressing 

concern about the HAF timeline and lack of recent engagement. The agency provided a 

written response. The comments helped shape the six completed engagement meetings 

since December 3, 2021 and a commitment to weekly and monthly updates. 

2. DevNW (a local homeownership center): Verbal comments expressing concern about the 

HAF timeline and lack of recent engagement. The agency followed up with a phone call to 

learn more about these concerns. The comments helped shape the six completed 

engagement meetings since December 3, 2021 and a commitment to weekly and monthly 

updates. 

U.S. Treasury’s feedback and questions were also placed on the agency’s website and emailed to 

several stakeholders for comment on four of the questions. We received responses from three 

individuals representing NeighborWorks Umpqua and DevNW, both homeownership centers that 

are agency partners. The responses were incorporated into this response, further changes to the 

program terms and Oregon portal response, and our planning and work that is not a full 

commitment conveyed in the HAF plan and program terms. 

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. 

Please refer to the uploaded Oregon HAF plan, including without limitation the needs analysis for 

more detailed information and citations. The agency completed its homeowner needs 

assessment based upon both quantitative and qualitative data listed in the HAF plan and portal 

application. The data informed our analysis of the mortgage landscape in Oregon (delinquency, 

forbearance, and foreclosure statistics and trends), the demographics of homeowners, the 

geographic distribution of homeowners, the economic hardships in Oregon, particularly 

pandemic related, and the cost burden of homeowners. The Oregon data and needs analysis was 

shared with stakeholders and the public and feedback was incorporated into the HAF plan. The 

data helped shape the program terms, program priority populations for application processing 

and targeted outreach, the phases for our phased opening focused on at-risk and traditionally 

underserved homeowners, our performance goals, and our related procurements and 

opportunities, including funding for community-based outreach for culturally-specific 

organizations or work. 
Oregon HAF – U.S. Treasury Feedback Responses 

Page 4 of 10

Oregon Housing and Community Services | 725 Summer St. NE Suite B, Salem, OR 97301-1266 | (503) 986-2000 | FAX (503) 986-2020 

 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)? 

Using a phased opening and our HAF application itself, Oregon designed and implemented a 

program with a de facto screening process and prioritization processing mechanisms. This will 

assist the agency in evaluating the immediate threats of foreclosure and to housing stability that 

our applicants may be experiencing. It will allow HAF program staff to prioritize the applicant 

and address any needs related to reinstatement or ongoing payments. The application itself will 

also help identify any housing costs or delinquencies (e.g. chattel loan actions) which may 

require a more expedited timeline. Oregon strongly encourages each applicant and each 

homeowner reviewing HAF materials to communicate with their mortgage servicer and/or a 

housing counselor in order to receive individual advice. We will refer homeowners with 

immediate threats to legal aid. 

 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 options. 

Our HAF program connects homeowners with housing counselors and legal services early in the 

process. Oregon strongly encourages each applicant and each homeowner reviewing HAF 

materials to communicate with their mortgage servicer and/or a housing counselor to receive 

individual advice. Prior to the submission of an application the homeowner has access to a full 

list of housing counselors and community partners statewide in which they can use to find the 

option nearest them. This list is accompanied by additional legal aid resources. A reiteration of 

these resources occurs throughout the application review process. 

Homeowners can access additional information or obtain assistance regarding engaging in loss 

mitigation options with their mortgage servicer by visiting one of the housing counseling 

agencies. Housing counselors will discuss applicable options and help them evaluate which 

options could be best to pursue given their situation. Housing Counselors can also provide 

updates and information about upcoming trainings or educational clinics regarding foreclosure 

prevention available to homeowners. We will refer homeowners with immediate threats to legal 

aid and will make a central legal aid intake available for homeowners with questions on their 

loss mitigation options. The agency will fund both counseling and legal assistance in the preforeclosure Oregon Foreclosure Avoidance program, which most servicers are required to 

participate if a homeowner opts into the program to discuss loss mitigation options. 
Oregon HAF – U.S. Treasury Feedback Responses 

Page 5 of 10

Oregon Housing and Community Services | 725 Summer St. NE Suite B, Salem, OR 97301-1266 | (503) 986-2000 | FAX (503) 986-2020 

 How will your program leverage resource 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? 

Oregon will leverage available loss mitigation options to homeowners. As discussed previously, 

Housing Counselors will be available to assist homeowners in understanding their options. 

Homeowners are repeatedly referred to housing counselors (and their mortgage servicers) in all 

of the HAF materials, in the HAF application process, and in public and individual 

communications with the agency. 

In our application, Applicants will be asked which loss options they have previously pursued or 

discussed with their mortgage servicer when completing the initial application as well as 

throughout the review process. This is another reminder that other options may be available. We 

hope to communicate with mortgage servicers directly in unique situations raised by housing 

counselors or homeowners. 

More broadly, Oregon’s phased opening and program prioritization on homeowners most at risk 

(active foreclosure, no loss mitigation options, etc.) effectively targets aid to homeowners that 

do not have other viable options. By focusing efforts on these specific categories of homeowners 

we help duce the potential that HAF funds would replace other viable relief options. We worked 

with stakeholders to confirm our phased opening targets homeowners without other viable 

alternatives, such as chattel loans, land sale contracts, unemployment without benefits, etc. 

Stakeholder feedback on this U.S. Treasury question confirmed the use of a phased opening will 

serve this purpose. A stakeholder also pointed out the availability of the Oregon Foreclosure 

Avoidance program that allows homeowners to request “sit down” loss mitigation review before 

a servicer may proceed to foreclosure, and the availability of counseling funds to assist with loss 

mitigation review as part of this program and outside of this program. Finally, a stakeholder 

pointed out that counselors understand the servicer loss mitigation waterfall, including COVIDspecific options, and are in a better position to evaluate whether a servicer’s denial of options is 

legitimate. 

 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? 

Oregon’s programs will not be modifying loans, unless completed in collaboration with a servicer 

option, so homeowners will be working with existing loan terms. This will likely only come up if 

the changed homeowner condition or hardship has impacted the ability to pay, permanently or 

temporarily. 

The past-due payment relief program sets an affordability standard using the housing cost 

burden ratio of 43% based on traditional mortgage estimates and the agency’s desire to use a 

higher percent at this time to account for a delta of moderate changes in circumstances. If 1) a 

homeowner’s application shows a housing cost burden of 43% or below, 2) a counselor confirms 

the payment will be affordable, or alternatively 3) the homeowner attests that they can afford 

their payments, they qualify for reinstatement assistance. 
Oregon HAF – U.S. Treasury Feedback Responses 

Page 6 of 10

Oregon Housing and Community Services | 725 Summer St. NE Suite B, Salem, OR 97301-1266 | (503) 986-2000 | FAX (503) 986-2020 

If a homeowner’s housing cost burden exceeds 43%, they will still qualify for reinstatement 

assistance if they qualify for ongoing payment relief. This will allow homeowners that need 

additional time or stability the opportunity to reinstate and attempt to improve their position, 

rather than face immediate foreclosure actions. Sustainability at the end of this process depends 

on if the homeowner is able to resume employment, obtain disability or other benefits, or 

transition from the home without adverse credit or financial impact. 

As mentioned elsewhere, Oregon does and will continue to refer homeowners to housing 

counselors in our informational materials, communications, and in the application itself. This 

importance, particularly to this question, was superbly summarized by a responding stakeholder: 

“This analysis is a cornerstone of foreclosure avoidance counseling performed by housing 

counselors. We undergo a deep dive of a homeowner’s financial situation, assessing their 

mortgage costs relative to other debt burdens/monthly expenses, and evaluate all workout 

options based on a potential payment change. If the payment relief is temporary, we work with 

homeowners to plan for eventually taking the mortgage back on (this may include paying down 

debt in the meantime so their debt obligations lessen once their mortgage resumes). If the 

resolution will change their monthly payment in the long-term, we assist them in analyzing both 

the stability on paperwork (e.g. the new housing ratio) plus the reality of what it means for their 

monthly budget and sustainability. Additionally, we connect them with other resources or 

options for lowering monthly expenses or debt as needed.” 

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

homeowners that HAF will serve? 

To avoid replacing viable alternative funding streams, Oregon HAF will not provide assistance 

with utility or energy housing costs as there are other programs available for homeowners. This 

cost is not factored into the housing cost burden calculation used for Oregon’s program. Oregon 

had not contemplated increased winter energy costs as a Qualified Financial Hardship as it is not 

related to the coronavirus pandemic. Oregon will consider how this factor might become part of 

the programs with additional guidance on whether or how it is a Qualified Financial Hardship 

related to the coronavirus pandemic. 

Eligibility 

 Please provide the rationale for establishing the following additional eligibility 

requirements specified in your plan, including how you determined these requirements 

will not create unnecessary barriers to participation by eligible homeowners. 

o No conviction in past 10 years for money laundering, fraud, or tax evasion. 

Oregon Housing and Community Services has implemented the feedback of Treasury and decided 

to remove this eligibility requirement from our programs as to reduce barriers or inequity. 
Oregon HAF – U.S. Treasury Feedback Responses 

Page 7 of 10

Oregon Housing and Community Services | 725 Summer St. NE Suite B, Salem, OR 97301-1266 | (503) 986-2000 | FAX (503) 986-2020 

Outreach 

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

with limited English proficiency. 

The agency plans to provide all informational HAF materials in five languages, a paper 

application, and either the online application itself or a summary in five languages. We are 

working out how we can provide the online application in our top five languages; due to cost and 

technology limitations, it may not be feasible. In Oregon, housing counselors and our intake 

partners will be required to have a language access plan to serve homeowners with limited 

English proficiency. Many provide assistance in another language. 

Oregon will serve limited English proficiency homeowners in phase three of its opening, providing 

those homeowners with additional time to complete an application, with or without assistance, 

before all eligible homeowners may apply. 

One of the responding stakeholders is ready to advocate for public service announcements with 

both larger listener radio stations on the southern Oregon cost, once the agency is prepared to 

accept and fund a higher volume of applications. Another responding stakeholder plans to work 

with trusted advisors, plans to provide Spanish radio ads and spotlights, provide cultural 

translation materials (not word for word), and provide an immediate Spanish service connection. 

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

The agency has provided pre-program initial foreclosure prevention information in presentations 

to BIPOC homeowners, including presentations in Spanish, based upon data that Black and 

Hispanic populations have a higher risk of foreclosure and displacement. The agency will 

continue its culturally relevant marketing using multiple languages for all materials, social media 

posts, and information targeting priority populations pursuant to our data and stakeholder and 

public feedback. 

In addition, based upon stakeholder feedback, the agency will fund marketing and outreach by 

community-based organizations, including culturally-specific organizations and rural 

organizations. The agency will assist with information for these activities but the trusted 

community partners will be able to provide marketing where, and in various methods, needed for 

each particular community or population. The agency has been engaged with organizations that 

are not housing partners to help raise awareness; these organizations may apply for marketing 

funding as well. 

Prioritization 

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

your program prioritize socially disadvantaged individuals? Please describe your marketing 

and outreach strategy to SDI communities? 

While Oregon’s ongoing payment assistance program will only serve homeowners at or below 

100% AMI for household size or 100% US median income, whichever is greater, the 

reinstatement program will serve homeowners up to 150% AMI. 
Oregon HAF – U.S. Treasury Feedback Responses 

Page 8 of 10

Oregon Housing and Community Services | 725 Summer St. NE Suite B, Salem, OR 97301-1266 | (503) 986-2000 | FAX (503) 986-2020 

Oregon plans to prioritize homeowners in four categories: low-income households (100% AMI 

and below), SDI households, rural households, and homeowners most at risk of foreclosure. To 

ensure these are prioritized we have developed a matrix tool which takes into consideration 

various responses from the application. In this way we are operationalizing SDI prioritization. 

Applicants may self-identify as SDI and the agency may flag certain applications based upon 

other application questions and/or our fact-based proxy prioritization tool. 

Although Oregon’s reinstatement program intends to serve households who are over the 100% 

AMI threshold, we are aware that continual outreach and efforts should be made to these 

communities as to ensure adequate access to resources. 

Stakeholder feedback on this question pointed out that rural Oregon homeowners that do not 

fall within the low-income threshold still satisfy the rural part of the SDI definition. Another 

responding stakeholder plans to work with trusted advisors to SDI populations (but may not 

provide housing services), plans to provide Spanish radio ads and spotlights, provide cultural 

translation materials (not word for word), and provide an immediate Spanish service connection. 

Performance Goals 

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

public? 

OHCS will implement a publicly available program performance dashboard that will be published 

on our website. This dashboard will be updated on a frequent basis as to provide program 

transparency. The agency has also developed a communications strategy to provide frequent 

updates in various formats as well as updates to our agency website. 

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

program. 

1. Number of homeowners served. We anticipate serving 1,000 homeowners if each receives 

the maximum award. We hope to serve more homeowners, particularly at lower income 

levels and SDI populations. We hope to serve homeowners in representative percentages as 

to the state homeownership rates for BIPOC and rural homeowners. 

2. Statewide serious delinquency rate (90+ days). We hope HAF and the other available 

programs will help homeowners exit forbearance into workable reinstatement or loss mitigation 

options. Our goal is to reduce the delinquency rate from 2.6% at the time of the HAF plan to the 

1% pre-pandemic average. 

3. Foreclosures and displacement avoided. To the extent that we can accurately track this 

statistic, we would like to report on the homeowners assisted that were in active foreclosure 

and/or had no other viable workout option. 
Oregon HAF – U.S. Treasury Feedback Responses 

Page 9 of 10

Oregon Housing and Community Services | 725 Summer St. NE Suite B, Salem, OR 97301-1266 | (503) 986-2000 | FAX (503) 986-2020 

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

OHCS will disaggregates data based on race, ethnicity, gender, geography, education, and other 

factors, when possible, to demonstrate the needs of those groups that have been traditionally 

excluded from homeownership opportunities and wealth generation, particularly communities of 

color, LGTBQIA persons, and women. 

 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 are considering how to best to track and report these statistics. 

Readiness 

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

including staffing, contractors, etc. 

Oregon has hired additional staff since submission of its plan, plans to hire additional staff for 

the higher volume of applications expected in winter/spring 2022, and is finishing up 

procurements that will enable it to serve Oregonians through local outreach and marketing, with 

intake assistance, with legal aid, and with application processing and customer service support. 

Oregon has completed an extensive state review of its HAF development and operational plan, 

including information security and various processes, which has all been reviewed by an 

independent quality management specialist. Further, Oregon opened HAF to Phase 1 applicants 

and is currently processing applications in this low-volume phase focused on high-risk 

homeowners. 

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

to launch following approval? 

Oregon is currently open and operating under a pilot program. Upon approval from Treasury and 

receipt of the additional funds OHCS will be able to move seamlessly from the low-volume first 

two phases of opening to the higher volume phase three, followed by opening to all eligible 

homeowners. We are currently finalizing procurements with contractors, which will provide 

further capacity to the program and Oregonians. We anticipate being ready to launch the higher 

volume phase three using our program administrator at the end of February 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. 

Oregon’s pilot program is open (consisting of phases one and two of the phased opening). 

Although no funds have been disbursed, we are processing applications. 

Budget 
Oregon HAF – U.S. Treasury Feedback Responses 

Page 10 of 10

Oregon Housing and Community Services | 725 Summer St. NE Suite B, Salem, OR 97301-1266 | (503) 986-2000 | FAX (503) 986-2020 

 Your total allocation amount is $90,927,920.00. Our records indicate that you have received an 

initial 10% payment of $9,092,792.00, and that upon plan approval, you may draw up to 

$81,845,128.00. 

o The total budget in your draft plan is for $78,985,498. Please confirm your budget is 

correct, and that at this time, you wish to receive less than your remaining allocation. If 

necessary, please revise your budget, including the initial 10% that was paid in your 

initial payment. 

 Your budget allocates $13,328,954.00 to administrative expenses, which is greater than 15% of 

the amount you have requested, the maximum permitted under HAF guidance. Please adjust 

your administrative expense budget so that it falls within the 15% limit. 

Oregon will request the full allocation and revise the administrative expenses.