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United States Department of the Treasury

Homeowner Assistance Fund Plan

Submitted by GOVERNMENT OF THE VIRGIN ISLANDS

HAF Grantee Plan Name

HAFP-0272
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United States Department of the Treasury

Homeowner Assistance Fund Plan For Participants 

with Allocations $5 million or Greater

Allocation Amount $5 Million or Greater

Submission Date 3/3/2022 11:22 AM

Total Plan Requested Amount $8,521,959.00

Record Type State

Application Record SLT-0070

HAF Grantee Plan Status (external) Approved
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Homeowner Needs and Community Engagement

What Quantitative Data Has Informed the Participant’s Planning?

Treasury will assess the extent to which a Participant has, in the course of its HAF planning process, relied on

quantitative data, including from community-based organizations or organizations that serve potentially

eligible homeowners. 

In its HAF planning process, has the Participant obtained quantitative data from mortgage servicers, private

data providers, government entities, community-based organizations, or other sources to inform its planning

about how to target and best serve eligible homeowners with mortgage delinquencies, defaults, foreclosures?

Yes

If yes, please list and, briefly describe each source of quantitative data.

Banco Popular de Puerto Rico - mortgage lender in the US Virgin Islands; portfolio includes

Conventional, FHA, USDA Guarantee, and VA mortgages

First Bank Virgin Islands - mortgage lender in the US Virgin Islands; portfolio includes

Conventional, FHA, and VA mortgages

Bank of St. Croix - mortgage lender in the US Virgin Islands; portfolio includes Conventional

and ARM mortgages

Government Employees Retirement System - mortgage lender in the US Virgin Islands; portfolio

includes locally government funded loans

Virgin Islands Housing Finance Authority - mortgage lender in the US Virgin Islands; portfolio

includes loccally funded government loans

In its HAF planning process, has the Participant obtained and reviewed quantitative data or studies regarding

which demographic segments in its jurisdiction have historically experienced discrimination in the housing or

housing finance market?

No

In its HAF planning process, has the Participant obtained quantitative data from utility providers or entities

charged with assessing and collecting property taxes or relied on quantitative data or studies to inform its

planning about how to target and best serve eligible homeowners at risk of displacement due to utility

arrearage or tax foreclosure?

No

In the following text box, please list any source not listed above of quantitative information, including

sources of data on the performance of any of the Participant’s previously implemented programs, that the

Participant used to inform its HAF planning process, briefly describe how the data informed the Participant’s

planning.

The Data contained information on the loan portfolios of various lending institutions in the

Territory. Using these statistics acquired, the Territory’s current delinquency rate is 11 percent

with the majority of these loans at 90 or more days delinquent. Based on the data received from
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various lending institutions, the HAF plan targeted populations most in need of these services.

The Authority will utilize this information to focus on outreach activities that meet the needs of

the residents of the Territory through public service campaigns. It should be noted that the

Territory is a majority-minority jurisdiction. Advertisements, social media posts, and brochures

will be prepared to reflect the many cultures and ethnicities of the Territory’s residents. This will

include the availability of the outreach materials in Spanish. 

The Virgin Islands Housing Finance Authority is also collaborating with the Office of the Lt.

Governor's Office of the Tax Collector to assess the number of delinquent property tax owners

affected by the COVID-19 pandemic.

Did the Participant communicate with mortgage servicers regarding the development of its program design?

Yes

Did the Participant communicate with other HAF participants regarding the development of its program

design?

Yes

How Has Community Engagement and Public Participation Informed the

Participant’s Planning?

Treasury will assess the extent to which a Participant’s assessment of homeowner needs has been informed

by and reflects input from organizations and individuals representing eligible homeowners, including any

opportunities for public participation in the development of the Participant’s plan. Treasury will pay

particular attention to the extent of the Participant’s engagement with populations that are the subject of

statutory targeting requirements.

Has the Participant requested and received input on its HAF planning process from providers of housing

counseling services or providers of legal assistance to homeowners facing foreclosure or displacement?

No

Has the Participant requested and received input regarding its HAF planning process from community-based

organizations or organizations that serve potentially eligible homeowners?

No

Has the Participant consulted with localities or tribal governments (cities, counties, or rural communities) in

its jurisdiction regarding the needs of eligible homeowners in its jurisdiction?

No

Has the Participant provided an opportunity for public input regarding its HAF Plan through public hearings

or published materials?

Yes

If yes, please indicate whether a proposed or draft plan was published, please describe where details about the

comment solicitation were posted, for how long, in what languages, and whether any efforts were made to

make the posting accessible to persons with disabilities or individuals without reliable internet access.
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The Virgin Islands Housing Finance Authority published the Territory's HAF Action Plan on the

Authority's website, vihfa.gov, for public review and comment. Media sources, including internet

and print, published the Notice of Availability of Funding to ensure wide distribution of the plan

to all residents of the Virgin Islands. Hard copies of the HAF plan were available at the VIHFA's

office in St. Thomas and St. Croix. The public comment period occurred for fourteen days from

October 29 to November 11, 2021. All comments were accepted through email and web

submission. The Authority published the HAF draft plan through various media sources during

November 2021 to solicit public comments for the development of the Homeowner Assistance

Fund. During the public comment period, the Authority has not receive any feedback regarding

the Territory’s HAF since the Plan was submitted. 

The developer of the Plan, VIHFA, is the primary entity in the Territory that serves low- and

moderate-income first-time homebuyers. As such, VIHFA has a unique understanding of how to

engage the target population. VIHFA has conducted numerous outreach campaigns over the

years including, but not limited to public ad campaigns (print and radio) as well as direct

outreach to large entities where large numbers of potential clients may be employed. VIHFA is

presently administering the Territory’s Emergency Rental Assistance Program (ERAP). The

Authority will partner with the lending institutions in the Territory to expand its outreach

initiatives and will focus on media campaigns that highlight the goals of the HAF. All entities will

collaborate to ensure that the targeted population is served.

How Will the Participant Continue to Assess the Needs of Eligible

Homeowners?

Treasury anticipates that an ongoing process of assessing the needs of eligible homeowners will help address

the needs of potentially eligible homeowners as economic conditions change over time.

Does the Participant plan to update its assessment of community needs within the next year to determine

whether its HAF program design should be updated to address changing needs of potentially eligible

homeowners?

Yes

What additional data would be helpful to the Participant as it seeks to assess homeowner needs over time?

The data was received from lending institutions operating in the US Virgin Islands. They include

Banco Popular de Puerto Rico, FirstBank VI, Bank of St. Croix, Government Employee

Retirement System, and the Virgin Islands Housing Finance Authority. Additional information

was received from the Lt. Governor’s Office of Banking and Insurance. These entities represent

all except one of the major mortgage lenders serving the Territory. At the request of the VIHFA,

these entities compiled loss mitigation statistics to be used for consideration of the populations to

be served through this grant. Although the available data did not address all of the specific

parameters requested, the VIHFA relied on the data as well as anecdotal evidence when

considering the program design. VIHFA is confident that the proposed program design is

sufficiently broad to serve the diverse needs of the targeted populations. Additional information

related to delinquent mortgagors may be required from the mortgage lenders and government

entities as the VIHFA continues to assess homeowner needs. This includes monthly data on loan

delinquency and default, statements regarding HOA and condo fees, and monthly documentation

on delinquent property taxes. 

As data is received, the Territory will incorporate any necessary changes to ensure that

homeowner needs are addressed. This may result in revisions to the HAF Plan that correspond to

the needs of the delinquent clients. US Treasury will be notified of any modifications made to the
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plan. 

The predominant non-English language found in the Territory is Spanish and there are no other

languages which occur in numbers that meet the threshold of other consideration. The VIHFA

employs bilingual staff, who will assist with marketing and outreach to LEP homeowners. The

VIHFA will continue to obtain input from the population to ensure the program meets the needs

of the community. 

As a Territory of the US, there are no tribal entities located in the U.S. Virgin Islands

jurisdiction.
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Program Design

What are the Program Design Elements Through Which the Participant Will

Deliver HAF Assistance to Eligible Homeowners?

A program design element is a specific activity or program, which is consistent with a qualified expense

category, under which a Participant will disburse HAF funds in accordance with the HAF Plan. Please note

that multiple program design elements may fit under a single qualified expense category; for example, a

mortgage assistance program that has different terms for federally backed mortgages and manufactured-home

mortgages may constitute two separate program design elements, for which case the Participant provides a

separate term sheet or other description for each program design element. 

HAF participants must have at least one program design element intended to reduce mortgage delinquency

among targeted populations. Treasury encourages HAF participants to consider program design elements that

address homeownership preservation for targeted populations in areas where there is a sustained trend of

increasing property taxes or utility costs, including for households that do not have mortgages.

Please identify each qualified expense category in which the Participant will offer a program design element

by checking the boxes below.

mortgage payment assistance 

 mortgage principal reduction, including with respect to a second mortgage provided by a nonprofit

or government entity 

 payment assistance for homeowner’s utilities, including electric, gas, home energy, and water 

 payment assistance for homeowner’s insurance, flood insurance, and mortgage insurance 

 payment assistance for delinquent property taxes to prevent homeowner tax foreclosures 

 payment assistance for down payment assistance loans provided by nonprofit or government

entities 

 financial assistance to allow a homeowner to reinstate a mortgage or to pay other housing-related

costs related to a period of forbearance, delinquency, or default 

facilitating mortgage interest rate reductions 

 payment assistance for homeowner’s internet service, including broadband internet access service,

as defined in 47 CFR 8.1(b) 

 payment assistance for homeowner’s association fees or liens, condominium association fees, or

common charges 

 measures to prevent homeowner displacement, such as home repairs to maintain the habitability of

a home or assistance to enable households to receive clear title to their properties 
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For each program design element that the Participant will offer, the Participant is required to upload a term

sheet or other description, that, at a minimum, provides the following information regarding that program

design element. Term sheets for all of Participant’s HAF programs may be uploaded together as one

document.

Title Upload Date

Performance Goals - HAF 3/3/2022 11:12 AM

Readiness - HAF 3/3/2022 11:20 AM

Program Design - HAF 3/3/2022 11:11 AM

HAF - Program Design elements 11/19/2021 3:14 PM

HAF Program Design elements 11/16/2021 9:16 AM

A HAF participant may elect to revise its HAF Plan over time to add or subtract program design elements.

Does the Participant anticipate adding additional program design elements to this HAF Plan within one year

of this submission?

Yes

Treasury has provided sample term sheets to assist HAF participants in developing their HAF plans.

Participants may use these sample term sheets, in whole or in part, as part of their submission. To the extent

the Participant intends to structure the program differently with respect to significant program terms

described in the Sample Term Sheets, Treasury will, in the course of its review of the HAF Plan, request a

justification for how the alternate approach will further the objectives of the HAF, including targeting and

prioritization requirements. In the chart below, the HAF Participant may provide a justification for significant

deviations from the terms described in the sample term sheets upon initial submittal. (optional for initial

submission)

Program Design Element Deviation from sample

terms Justification

Mortgage Loan Reinstatement Program No deviation n/a

Mortgage Payment Assistance Program No deviation n/a

Mortgage Principal Reduction Program No deviations at this time n/a

Homeowner Displacement Prevention No deviations at this timen.a

Homeowner Delinquent Property tax/Hazard Insurance

Prevention Program

No deviations at this time n/a

Documentation of Homeowner Income

Homeowners are eligible to receive amounts allocated to a HAF participant under the HAF only if they have

incomes equal to or less than 150% of the area median income or 100% of the median income for the United

States, whichever is greater. In addition, not less than 60% of amounts made available to each HAF
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participant must be used for qualified expenses that assist homeowners having incomes equal to or less than

100% of the area median income or equal to or less than 100% of the median income for the United States,

whichever is greater. The HAF guidance describes permissible ways for HAF participants to determine

homeowner income.

Under the HAF guidance, one permissible approach for determining income is for (1) the household to

provide a written attestation as to household income and (2) the HAF participant to use a reasonable

fact-specific proxy for household income, such as reliance on data regarding average incomes in the

household’s geographic area. Will the Participant allow income to be determined in this way?

No

Under the HAF guidance, HAF participants may provide waivers or exceptions to this documentation

requirement as reasonably necessary to accommodate extenuating circumstances, such as disabilities,

practical challenges related to the pandemic, or a lack of technological access by homeowners; in these cases,

the HAF participant is still responsible for making the required determination regarding household income

and documenting that determination. Will the Participant allow applicants to request such waivers or

exceptions?

Yes

Eligible Mortgage Types

Please indicate which of the following mortgage types are eligible to be assisted under one or more of the

Participant’s program design elements.

 First Mortgages 

 Reverse Mortgages (Home Equity Conversion Mortgages, Single-Purposes Reverse Mortgages, or

Proprietary Reverse Mortgages) 

 Contracts for Deed or Land Contract (if it is a credit transaction secured by a consensual security

interest in a dwelling) 

 Second Mortgages 

 Loans Secured by Manufactured Housing (secured by real estate or dwelling) 

If the Participant excludes any of the forgoing mortgage types from one or more program design elements,

explain the exclusion.

Reverse mortgages are not offered in the US Virgin Islands. The purchase of a manufactured

home is not funded through mortgage lenders.

How Will the Participant Target HAF Resources Consistent with Statutory

Requirements? 

The Participant must describe how it will target HAF resources in accordance with the HAF guidance.

Targeting strategies are affirmative efforts to inform, encourage the participation of, and facilitate access to

resources for targeted households, including by offering multiple intake formats, engaging with nonprofit

organizations (e.g., housing counselors or legal services organizations) to provide additional pathways into

the program, and providing community outreach, partnerships with housing counseling agencies or legal aid
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organizations, or other educational services that are aligned with the HAF participant’s program design, in a

manner that is culturally and linguistically relevant to the targeted communities.

Defining Socially Disadvantaged Individual

Please describe the process the Participant will use to determine whether a homeowner is a “socially

disadvantaged individual” as defined in the HAF guidance.

Demographical information obtained from the application will be used to determine whether a

homeowner meets the definition of a socially disadvantaged individual. HUD income Limits will

be utilized to determine eligibility. The Territory is mainly comprised of majority-minority

census tracts, with predominant African American and Hispanic American households. Given

the demographics of the community, the Marketing and outreach activities will naturally target

SDI individuals and these individuals will comprise the majority of persons served by the

program.

Public Communications

Will the Participant engage in a public communications campaign to raise awareness among targeted

populations about the availability of HAF resources, in media such as television, newspapers, online media,

or social media?

Yes

If yes, please indicate whether the public communications campaign will include communications that

primarily target the following populations:

 Homeowners earning less than 100% of area median income 

 member of a group that has been subjected to racial or ethnic prejudice or cultural bias within

American society; 

 resident of a majority-minority Census tract; (3) 

 resident of a U.S. territory, Indian reservation, or Hawaiian Home Land 

 homeowners in persistent poverty counties; 

 individual with limited English proficiency 

Please indicate in which languages, in addition to English, public communications to targeted populations

will be undertaken:

Spanish; Haitian Creole

Outreach

Will the Participant engage in outreach through partnerships with organizations that focus primarily on

serving homeowners earning incomes below 100% of area median income or socially disadvantaged

individuals and that have the capacity to engage targeted communities in a culturally and linguistically

relevant manner to encourage the submission of applications for HAF resources from targeted populations?
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Yes

If yes, please indicate whether the community outreach efforts will include partnerships with organizations

that primarily target the following populations:

 member of a group that has been subjected to racial or ethnic prejudice or cultural bias within

American society; 

 resident of a majority-minority Census tract; (3) individual with limited English proficiency; 

 resident of a U.S. territory, Indian reservation, or Hawaiian Home Land;

 homeowners that reside in persistent poverty counties; 

 individual with limited English proficiency. 

Housing Counseling and Legal Services

Will the Participant facilitate access for eligible households to housing counseling or legal services?

Yes

If yes, please identify below the providers of housing counseling or legal services that have indicated to the

Participant that they are willing and able to support homeowners receiving assistance under the Participant’s

HAF programs. 

Provider Name 

Provider Address 

Provider Website

Provider

Primarily

Serves

LMI

Households

Provider

Addresses

Impact of

Housing

Discrimination

Virgin Islands Housing Finance Authority

3202 Demarara Plaza Suite 200 , St. Thomas, Virgin Islands 00802

http://www.vihfa.gov

Targeting specific groups of homeowners

Will the Participant conduct outreach specifically tailored to target potentially eligible households that:

 have mortgages or mortgage assistance contracts held or backed by the Participant? 

 have mortgages backed by any of the following agencies: Federal Housing Administration;

Department of Veterans Affairs; U.S. Department of Agriculture? 

 have privately held mortgages? 

What Efforts will be Made to Address Barriers to HAF Program Participation for

Potentially Eligible Homeowners, Including Those with Limited English

Proficiency or Who are Disabled?
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Targeted outreach may be needed to reach homeowners who are likely to experience barriers to access,

including persons with limited English proficiency and those with disabilities.

Indicate all of the languages, in addition to English, in which the Participant’s HAF application and other

program documents will be made available.

Spanish; Haitian Creole

Will the Participant’s HAF applications and other program documents be provided in forms that are

accessible to persons with disabilities?

Yes
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Performance Goals

Treasury will consider the goals and benchmarks the Participant proposes to use to measure the effectiveness

of its programs, including whether those goals address the homeowner needs identified by the Participant, the

extent to which the goals are disaggregated by key homeowner characteristics as appropriate for the

jurisdiction, and whether they include a goal focused on reducing mortgage delinquency.

Please describe Participant’s goals and benchmarks for each of its programs with the following program

design elements.

Program Design Element Metric of Success Goal

Mortgage Payment

Assistance

Number of home losses avoided by eligible homeowners who

received program funds

Assist 70

households

Payment Assistance for

Delinquent Property Taxes Number of homeowners who received program funds to assist

with maintaining taxes, insurance, and other assessments

Assist 7

households

Mortgage Reinstatement Number of home losses avoided by eligible homeowners who

received program funds

Assist 180

households

Mortgage Principal

Reduction

Number of home losses avoided by eligible homeowners who

received program funds

Assist 40

households

Payment Assistance for

Homeowner’s Insurance

Number of homeowners who received program funds to assist

with maintaining homeowner's or flood insurance

Assist 7

households

Payment Assistance for

HOA fees or liens

Number of homeowners who received program funds to assist

with condominium association fees

Assist 6

households

Other measures to prevent

homeowner displacement

Number of home losses avoided by eligible homeowners who

received program funds

Assist 15

households
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Readiness

Staffing, Systems and Contractors 

Treasury seeks information regarding the Participant’s organizational capacity to implement its HAF Plan.

Does the Participant anticipate needing to hire additional staff to implement this HAF Plan?

Yes

Does the Participant anticipate significant information technology system upgrades to implement this HAF

Plan?

Yes

Does the Participant have policies or procedures that govern the implementation of each HAF program

design element described in this HAF Plan?

No

If no, is a policy and procedure in development for each HAF program design element described in this HAF

Plan?

No

Will the Participant use HAF funds to assist eligible households through a program that was operational

before the Participant first received HAF funds?

No

Will the Participant use any third-party contractor or partner to conduct program administration (such as

reviewing applications, determining eligibility, processing payments, conducting reporting, and reviewing

compliance) for some or all of the Participant’s HAF programs?

No

Use of Initial Payment

If the Participant has already received any HAF funds from Treasury, provide the following information

about the use of such funds as of June 30, 2021.

What amount of the HAF funds that the Participant has received been disbursed to eligible homeowners?

$0.00

Has the Participant begun accepting applications from homeowners for any HAF-funded programs?
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No

How much of the HAF funds that the Participant has received been obligated?

$0.00

Provide a brief description of how the Participant has used the HAF funds it has received.

As of June 30, 2021, there were no HAF funds expended.
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Budget

Budgeting of HAF Funds by Program Design Element 

Specify the amounts of HAF funds that the Participant proposes to allocate to each of the following program

design elements, if offered:

Measure Amount

Mortgage Payment Assistance $1,750,000.00

Mortgage Principal Reduction $1,000,000.00

Payment Assistance for Homeowner’s Internet Service $0.00

Payment Assistance for HOA fees or liens $30,000.00

Payment Assistance for Delinquent Property Taxes $35,000.00

Mortgage Reinstatement $4,500,000.00

Facilitate Mortgage Interest Rate Reduction $0.00

Payment Assistance for Homeowner’s Insurance $35,000.00

Payment Assistance for Down Payment Assist. Loans $0.00

Payment Assistance for Homeowners Utilities $0.00

Other measures to prevent homeowner displacement

Measure Amount

Foreclosure Prevention $375,000.00

Displacement Prevention Sub-Total $7,725,000.00

Counseling or Legal Services

The Participant may allocate up to 5% of its HAF funds for counseling or educational efforts by housing

counseling agencies approved by the Department of Housing and Urban Development or a tribal government,

or legal services, target to households eligible to be served with funding from the HAF related to foreclosure

prevention or displacement.
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Specify the Participant’s allocations for the following Amount

Counseling or Educational Services $0.00

Legal Services $0.00

Services Sub-Total $0.00

Reimbursement of Funds Expended After January 21, 2020

As described in the HAF guidance, HAF funds may be used for reimbursement of certain expenses between

January 21, 2020 and the date when the first HAF funds are disbursed by the HAF participant under the HAF

for a qualified expense (with certain limitations, as set forth in the HAF guidance).

Type of Expense Amount

N/A $0.00

Reimbursement Sub-Total $0.00

Allocation of Administrative Expenses

Type of Expense Amount

Administrative expenses will include staff/management costs $796,959.00

Administrative Expenses Sub-Total $796,959.00

Total Plan Requested Amount $8,521,959.00

Amount Requested Confirmation:

Yes
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Contacts

Please identify up to three contacts for the Participant- a primary contact, a designated point of contact for

reporting, and an additional contact.

Primary Contact

Name: Valdez Shelford

Agency/Office: Virgin Islands Housing Finance Authority

Email: vshelford@vihfa.gov

Phone Number: 3407774432

Reporting Contact

Name: Janine Hector

Agency/Office: Virgin Islands Housing Finance Authority

Email: jhector@vihfa.gov

Phone Number: 3407724432

Additional Contact

Name: Chivonne Moorhead

Agency/Office: Virgin Islands Housing Finance Authority

Email: cmoorhead@vihfa.gov

Phone Number: 3407724432

Proprietary or Otherwise Non-Public Information

Does your plan submission include any information or materials that are proprietary or otherwise non-public?

No

If "Yes," please indicate which information or materials are proprietary or otherwise non-public.
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Title VI Assurances

You must provide on behalf of the HAF Participant assurances that the HAF Participant will comply with

Title VI of Civil Rights Act of 1964. Please download the assurances, then review, sign, and upload the

signed copy to this page before submitting the HAF Plan.

Title Upload Date

Title VI Assurance 11/17/2021 2:55 PM
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Official Certification

I (the undersigned) certify that the information provided in the HAF submission is accurate and complete

after reasonable inquiry of people, systems, and other information available to the HAF Participant. The HAF

participant and I acknowledge that any materially false, fictitious, or fraudulent statement or representation

(or concealment or omission of material fact) in this submission may be the subject of criminal prosecution

under the False Statements Accountability Act of 1996, as amended, 18 U.S.C. § 1001 and also may subject

me and HAF Participant to civil penalties and/or administrative remedies for false claims or otherwise,

(including 31 U.S.C. §3729 et seq.). I am an authorized representative of HAF Participant with authority to

make the above certifications and representations on behalf of the HAF Participant.

Name of HAF Participant:

GOVERNMENT OF THE VIRGIN ISLANDS

Name and Title of Certifying Official

Name: Daryl Griffith

Title: Executive Director, VIHFA

Telephone: 3407724432

Email: dgriffith@vihfa.gov