GREG GIANFORTE SCOTT OSTERMAN

GOVERNOR DIRECTOR

COMMERCE.MT.GOV

301 S. PARK AVE. | PO BOX 200501 | HELENA, MT 59620-0501 | P: 406.841.2700 | F: 406.841.2701 | TDD: 406.841.2702

HAFP-0057- State of Montana

Treasury Feedback for Resubmission of Plan

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

Completeness 

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

unresponsive: 

• Your plan lists Cheryl Cohen as the Authorized Official, while the original 

application for HAF payments was signed by Scott Osterman. 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, please submit a request by 

email to HAF@treasury.gov. 

Scott Osterman sent a request to establish Cheryl Cohen as a new authorized 

representative for HAF payments to the email address provided on December 

14. Email below. 

From: Osterman, Scott <scott.osterman@mt.gov> 

Sent: Tuesday, December 14, 2021 10:03 AM

To: HAF@treasury.gov

Cc: Cohen, Cheryl <Cheryl.Cohen@mt.gov>; Schafer, Adam <ASchafer@mt.gov>

Subject: Establish new authorized representative for Montana HAF payments

Importance: High

Greetings,

The State of Montana would like to establish a new authorized representative for HAF 

payments. I, Scott Osterman, executed the original HAF Notice of Funds Request and Financial 

Assistance Agreement in my capacity as Director for the State of Montana Department of 

Commerce. The Housing Division with the Department of Commerce will be the lead 

administrator for the HAF program. 

The Housing Division includes the Montana Board of Housing (MBOH), which is our statewide 

Housing Finance Agency that is administratively attached to Commerce. The Board allocates 

housing credits for the development of affordable rental homes and issues tax exempt bonds for 

affordable single family homeownership programs and serves those loans in-house. The Housing 

Division also includes the Rental Assistance Bureau, which is our statewide Public Housing 

Authority that administers several federal rental assistance programs like Housing Choice 

Vouchers. Finally, the Housing Division administers multiple HUD Community Planning and 

Development programs for production and preservation of affordable housing, including HOME 

and HTF.
SCOTT OSTERMAN GREG GIANFORTE

DIRECTOR GOVERNOR

COMMERCE.MT.GOV

301 S. PARK AVE. | PO BOX 200501 | HELENA, MT 59620-0501 | P: 406.841.2700 | F: 406.841.2701 | TDD: 406.841.2702

Cheryl Cohen is the Housing Division Administrator and the Executive Director of the Montana 

Board of Housing. Given these roles, the State of Montana requests Cheryl Cohen to be 

established as an authorized representative for HAF payments.

Regards,

Scott

SCOTT OSTERMAN

Director

MONTANA

DEPARTMENT OF COMMERCE

T: 406.841.2745

COMMERCE.MT.GOV

Homeowner Needs and Community Engagement 

Data 

• No questions 

Community Engagement and Public Participation 

• Please describe any coordination you intend with Tribes or Tribal entities. 

We have made multiple outreach attempts through various channels – including 

via the Governor’s Office of Indian Affairs, stakeholder groups collaborating on 

single family housing needs for Native Americans and via trusted Tribal 

members with whom we have established relationships - to engage Tribal 

governments and Tribal entities. 

During our call on November 22, Treasury representatives indicated they would 

be willing to provide a list of contacts from Tribal governments or Tribal entities 

who have applied for HAF so we can connect with those specific individuals.

Vicki Bauer, Homeownership Program Manager, sent a follow up email to 

Treasury representatives on December 2 and met with Luis Saucedo on 

December 13. Vicki Bauer has provided Mr. Saucedo with a list of Tribal entities 

in the state of Montana.

We also met with the Governor’s Office of Indian Affairs Director Misty Kuhl on 

December 9. Director Kuhl is working this week to identify appropriate housing 

contacts at each reservation and will provide a contact list to us for continued 

outreach and coordination efforts. 
SCOTT OSTERMAN GREG GIANFORTE

DIRECTOR GOVERNOR

COMMERCE.MT.GOV

301 S. PARK AVE. | PO BOX 200501 | HELENA, MT 59620-0501 | P: 406.841.2700 | F: 406.841.2701 | TDD: 406.841.2702

• 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. 

We have not received any further public comment on our HAF Plan.

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. 

We assessed data from a variety of sources, including the Federal Reserve 

Bank of Atlanta’s Mortgage Analytics and Performance Dashboard, and other 

State-By-State Ranking Reports released by Black Knight Financial 

Technology Solutions, LLC. Both data sources are proprietary, so exact rates 

cannot be released. However, Black Knight’s First Look at June 2021 

Mortgage Data released July 22, 2021 reflects Montana in the bottom 5 of 

states by non-current percentage at 3.09%.1

A survey of non-depository mortgage companies in the state revealed that 

1,338 loans, accounting for $197,116,619 in unpaid principal loan balances, 

were more than 90 days delinquent at the end of 2021 Q1, an increase of 

nearly 2% from 2020 Q1. Among USDA loans in the state, over 300 loans are 

90 + days delinquent, nearly 5% of all USDA loans. Among Federal Housing 

Administration loans in the state, 1,546 are 90 + days delinquent, 

representing over 8% of all FHA loans. 2

American Community Survey 1-Year Estimates for 2019 data reports 166,220 

housing units with a mortgage in the state. Assuming a 3% delinquency rate for 

Montana results in approximately 5,000 borrowers. Only a subset of this 

universe will meet HAF program requirements, including income eligibility, 

primary residence, and COVID-19 financial hardship. While FHA and USDA-RD 

data indicates higher delinquency rates, borrowers with these or other 

government insured loans have access to other loss mitigation options. 

Therefore, we estimated 1,000 borrowers may be in need and eligible for our 

proposed HAF reinstatement loan program. 

• 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)? 

1 Black Knight's First Look at June 2021 Mortgage Data – Black Knight, Inc. (blackknightinc.com) 2 Data to Support HAF Plans for Montana Prepared June 11, 2021 by U.S. Department of the Treasury
SCOTT OSTERMAN GREG GIANFORTE

DIRECTOR GOVERNOR

COMMERCE.MT.GOV

301 S. PARK AVE. | PO BOX 200501 | HELENA, MT 59620-0501 | P: 406.841.2700 | F: 406.841.2701 | TDD: 406.841.2702

Our pilot program application for Montana Board of Housing borrowers does 

include the following yes/no statements about whether the borrower is in 

imminent risk of displacement which would result in a prioritization:

 My household has received a foreclosure notice

 My household has received a utility shut-off notice

 My household has received an internet shut-off notice

Additionally, our foreclosure specialist will assess whether the borrower is within 

120 days of foreclosure.

• Please clarify under which circumstances homeowners with contracts for deed 

or land contracts will be eligible or ineligible for the program. 

As indicated in our initial HAF Plan submission, this will be determined on a 

case-by-case basis. Our review will determine who is the deed holder and 

whether there is a right-to-encumber option on the deed. For land contracts, we 

will determine whether there is a home (mobile home) on the property where the 

borrower could be displaced if payment is not made. 

• 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.

Montana has a robust housing counseling network that is administered by 

NeighborWorks Montana (NWMT) and includes local provider partners of 

homebuyer education and counseling that span the entire state and all 

seven Indian reservations. NWMT recently applied for and received

funding through the Housing Stability Counseling Program (HSCP) via

NeighborWorks America. The funds are to be used for housing counseling 

and will provide direct assistance to households facing housing instability. 

Funds will also support housing counselor education, outreach, training, 

and operational oversight. 

Under this new HSCP funding, NWMT is building the capacity to ask 

clients seeking counseling to complete a NWMT assessment survey so 

their counseling needs can be evaluated. The assessment is an important 

first step, as it will help determine if there is a crisis that needs immediate 

mitigation through the Emergency Rental Assistance Program, the 

Homeowner Assistance Fund, or Montana Legal Services Association. 

Clients interested in home purchase services and those who do not 

believe they are facing housing instability will work directly with their local 

counseling organization on the services relevant to them.

The NeighborWorks America HSCP funding is only available until 

February 2023. 
SCOTT OSTERMAN GREG GIANFORTE

DIRECTOR GOVERNOR

COMMERCE.MT.GOV

301 S. PARK AVE. | PO BOX 200501 | HELENA, MT 59620-0501 | P: 406.841.2700 | F: 406.841.2701 | TDD: 406.841.2702

We propose use of HAF funding to extend and support the network in its 

counseling efforts until September 2025, which will provide additional 

stability for the network, its partners and employed counselors. 

In preliminary conversations with the Montana Legal Services Association 

(MLSA), we have discussed adding legal services for Montanans facing 

foreclosure to the existing Montana Eviction Intervention Project (MEIP)

program. MLSA would hire attorneys and legal assistants to represent 

Montanans to advise them on their legal rights in foreclosure 

proceedings, provide legal representation in court or administrative 

proceedings when appropriate, and help clients work with banks and 

creditors to stay housed, or access other housing supports.

• How will your program leverage resources available through a loss mitigation 

process to benefit eligible homeowners?

While our initial HAF Plan submission indicated a ‘No Help’ letter would be the 

best way to determine that other loss mitigation options had been exhausted, 

based on further clarity from Treasury representatives during our November 22 

call and subsequent team discussion, we will include a more nuanced approach 

in assessing the loss mitigation options offered to the borrower by their 

mortgage servicer, and the steps the borrower has taken (or not) in pursuit of 

those loss mitigation options. 

While some borrowers may be able to clearly articulate and identify the various 

loss mitigation options offered and pursued, we believe other borrowers may be 

less able to accurately identify these options from an itemized list. Therefore, we 

will include ways for borrowers to self-disclose these details within the 

application process but will also engage their mortgage servicer for confirmation 

of loss mitigation options offered to and pursued by their borrower. 

We believe this approach will help us prioritize HAF assistance for borrowers 

who lack other loss mitigation options, or for whom other available loss 

mitigation options are insufficient to stabilize their housing. In some cases, it will 

be in the borrower’s best interest to utilize other loss mitigation options to take 

advantage of loan modifications such as reduced interest rate or an extended 

loan term. Borrowers who may have maxed out their benefit from their 

mortgage insurer would then be potentially eligible to use the HAF program to 

become fully current. Older loans may have less options because they have less 

left on their mortgage and insurance will only have 30% available for lossmitigation.

As we proceed with our pilot program, we will gain further knowledge on how to 

leverage resources through various loss mitigation options available to eligible 

homeowners. 

• 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?
SCOTT OSTERMAN GREG GIANFORTE

DIRECTOR GOVERNOR

COMMERCE.MT.GOV

301 S. PARK AVE. | PO BOX 200501 | HELENA, MT 59620-0501 | P: 406.841.2700 | F: 406.841.2701 | TDD: 406.841.2702

Our program will require that the borrower be reviewed by their servicer for 

other loss mitigation options prior to being approved by for the HAF Program. 

Through those other options, the borrower may be able to take advantage of 

principal reductions, interest rate reduction or term extensions that could result 

in a lower monthly payment. Our proposed reinstatement program would not 

result in changes to the borrower’s monthly payment amount; the borrower will 

attest that they are able to continue making the payment that they were qualified 

for when they purchased their home. 

• Your term sheet for the reinstatement program indicate that assistance will be 

provided through non-forgivable loans, repayable at the end of the first 

mortgage (repayment, refinance, transfer or sale), with repayment subject to 

review at that time. Please explain how your program will determine when 

repayment is not required. Also, please explain your rationale for structuring 

other programs as grants rather than repayable loans. 

At the time the HAF loan becomes due, if there has been a decrease in the 

value of the property and by paying back the HAF loan, the borrower is in a 

negative equity position, writing off the HAF loan may be an option. 

Work out options offered by mortgage insurers and investors allow borrowers to 

obtain a partial claim in the form of a subordinate loan or to capitalize the 

delinquency and have it added to the end of the first mortgage loan. By offering 

the HAF funds as a loan rather than a grant, it will provide similar work out 

options to qualifying borrowers. 

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

impact on the homeowners that HAF will serve? 

We do anticipate increased winter home energy costs. The US Energy 

Information Administration provided a recent report indicating that retail prices 

for energy are at multiyear highs and that households will spend more on energy 

costs to heat their homes this winter compared to last year. Natural gas costs 

could see an increase of 30%-50%, electricity costs 6%-15%, and propane costs 

at 54%-94% depending on how cold the winter gets. As noted in our response to 

budget questions below, we are increasing our budget for home energy costs to 

benefit homeowners in our HAF program. 

Furthermore, we are aware that the Administration for Children & Families Office 

of Community Service, in conjunction with the U.S. Department of the Treasury, 

provided clarification on November 18, 2021 stating that “Eligible households 

can receive both LIHEAP and ERA benefits (i.e., receiving benefits from one 

program does not preclude a household from receiving benefits from the other 

program)”. Additionally, Treasury updated their webpage to provide additional 

promising practices for coordination with other utility assistance programs and 

LIHEAP.
SCOTT OSTERMAN GREG GIANFORTE

DIRECTOR GOVERNOR

COMMERCE.MT.GOV

301 S. PARK AVE. | PO BOX 200501 | HELENA, MT 59620-0501 | P: 406.841.2700 | F: 406.841.2701 | TDD: 406.841.2702

We will continue to coordinate with our state Department of Public Health and 

Human Services who administers Montana’s LIHEAP Program, to ensure 

coordination and collaboration between LIHEAP, ERA and HAF to the maximum 

benefit of eligible Montanans. The state’s LIHEAP benefits for this year have 

been increased by 50% (using ARPA funds) to provide additional assistance to 

eligible households. DPHHS is also monitoring the fuel cost increases and may 

provide a supplemental benefit for propane and natural gas customers in 

February/March if there continues to be significant need.

New Treasury guidance on promising practices noted that “Increased utility or 

home heating costs in light of pandemic-related heating cost increases” could be 

an indicator for Covid related financial impact. We will consider this guidance in 

our HAF implementation. 

• Your program set $25,000 as the maximum amount of reinstatement assistance 

per homeowner. Please explain how you determined this amount will be 

sufficient to resolve housing-related delinquencies and whether the cap will be 

sufficient in areas with higher housing costs?

At the time we put together our plan, we calculated 12 payments at 

$2,000/month and rounded up to $25,000. The $2,000 monthly mortgage 

payment is based on our experience in the single-family homeowner industry –

both origination and servicing – Montana home purchase prices, underwriting 

standards and the HAF program income eligibility restrictions. We believe this is 

a reasonable estimate of the average mortgage payment for HAF eligible 

borrowers in our state. 

Based on experience within our own portfolio, borrowers who requested a 

forbearance are, on average, 8 months behind on payments. Many of those 

borrowers have been able to resume making their monthly payment, they are 

just having a hard time making up the delinquency. Therefore, we believe 

$25,000 should be an adequate amount to cover the delinquent amounts, even 

in higher cost areas.

Eligibility

• Please provide additional information on the requirement that HAF assistance 

be repaid by the homeowner, including any research to determine whether this 

requirement would be burdensome on eligible homeowners.

Fannie Mae, Freddie Mac, FHA, USDA-RD and VA all have loss mitigation 

options available for borrowers. These options include:

* a payment plan or making a higher monthly mortgage payment than the 

regular payment until the default is made up

* payment deferral which puts missed monthly payments into a payment due 

at the sale or refinance of the mortgage or at the end of the loan

* loan modification which extends the number of years the borrower has to 

repay the loan and possibly lowers the interest rate, both of which result in 

a lower monthly payment
SCOTT OSTERMAN GREG GIANFORTE

DIRECTOR GOVERNOR

COMMERCE.MT.GOV

301 S. PARK AVE. | PO BOX 200501 | HELENA, MT 59620-0501 | P: 406.841.2700 | F: 406.841.2701 | TDD: 406.841.2702

All these options equate to the borrower paying back the full amount they 

originally borrowed to purchase the home rather than having a portion of the 

loan paid back on their behalf through a grant.

Having the option to write off the HAF loan will help ensure the HAF loan will not 

be burdensome to eligible homeowners.

• Please provide the rational for not using a fact-specific proxy as one method for 

establishing eligibility under your plan, including how you determined that 

without such proxy, your program can avoid unnecessary barriers to 

participation by eligible homeowners.

To align with our ERA program, we are not contemplating fact-specific proxy for 

determination of income eligibility. We are committed to avoiding unnecessary 

barriers in our HAF program and believe requesting income documentation in 

the form of IRS Tax Returns or two months most recent source documentation, 

as well as exceptions such as self-attestation for zero income status, is a low

barrier approach. Homeowners were required to provide income documentation 

to qualify for their initial loan and their respective mortgage servicers will likely 

also require income documentation for any loss mitigation options, including a 

HAF reinstatement loan. 

• Please specify the criteria for an eligible financial hardship and income 

requirements for the State of Montana’s HAF program.

The applicant must self-attest to experiencing a financial hardship relating to 

Covid after January 21, 2020. The attestation must describe the nature of the 

financial hardship, e.g., job loss, reduction in income, or increased costs due to 

healthcare or the need to care for a family member. It is our presumption, based 

on Treasury ERA guidance and flexibility for ERA applicants to self-attest to a 

financial hardship due, directly, or indirectly, to COVID-19, that Treasury will 

also permit applicants in the HAF program to self-attest to this criterion. 

For the purposes of determining income eligibility, Montana will use HUD’s 

definition of “annual income” in 24 CFR 5.609 or use adjusted gross income as 

defined for purposes of reporting on Internal Revenue Service (IRS) Form 1040 

series for individual federal annual income tax purposes. HAF applicants will be 

required to provide income documentation, such as 2020 IRS Tax Returns or 

two months recent income source documentation. Exceptions will be

permissible, such as self-attestation of borrower zero-income status. We will 

strive for the application process to be low-barrier, but we also recognize 

borrowers will have information available since mortgage servicers will need to 

gather income documentation for their review of loss mitigation options as well.

• Your program requires that homeowners applying for mortgage reinstatement 

assistance have exhausted their loss mitigation options prior to receiving 

assistance, and provide documentation from their servicer in the form of a “No 

Help Letter” or a copy of their current repayment plan. Please explain your 

rationale for requiring the homeowner provide such documentation, and whether 

you have considered alternative means of determining that the homeowner has 
SCOTT OSTERMAN GREG GIANFORTE

DIRECTOR GOVERNOR

COMMERCE.MT.GOV

301 S. PARK AVE. | PO BOX 200501 | HELENA, MT 59620-0501 | P: 406.841.2700 | F: 406.841.2701 | TDD: 406.841.2702

attempted to obtain a loss mitigation resolution. Please indicate any input you 

have received from other mortgage servicers, housing counselors, or housing 

advocates concerning this requirement. 

Treasury guidance states: ‘To the extent that HAF participants use HAF funds to 

supplement other loss-mitigation efforts, Treasury encourages participants to 

avoid using HAF funds in a manner that replaces other loss-mitigation resources 

that would otherwise be available.’ While our initial HAF Plan submission 

indicated a ‘No Help’ letter would be the best way to determine that other loss 

mitigation options had been exhausted, based on further clarity from Treasury 

representatives during our November 22 call and subsequent team discussion, 

we will include a more nuanced approach in assessing the loss mitigation 

options offered to the borrower by their mortgage servicer, and the steps the 

borrower has taken (or not) in pursuit of loss mitigation options they have been 

offered. 

While some borrowers may be able to clearly articulate and identify the various 

loss mitigation options offered and pursued, we believe some borrowers may be 

less able to accurately identify these options from an itemized list. Therefore, we 

will include ways for borrowers to self-disclose these details within the 

application process but will also engage mortgage servicers for confirmation of 

loss mitigation options offered to and pursued by their borrower. 

Outreach 

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

homeowners with limited English proficiency. 

Through our coordination with the NeighborWorks Montana Homeownership

Counseling Network, we understand that in fiscal year 2020, 2.1% of their 

clients were Limited English Proficiency. In fiscal year 2021, this decreased to 

1.5% of clients. Per census data, less than 0.2 of 1% of Montana residents do 

not speak English. In addition, 0.4 of 1% are considered to “not be proficient” at 

speaking English. NeighborWorks Montana has not received a single request for 

translation services in the last few years; however, they do have a process for 

connecting clients with translation services upon request, including a referral 

form. 

This is similar to our experience with administration of the Montana Emergency 

Rental Assistance program, which to-date has received one request for 

translation services. We will accommodate all requests and are aware of a 

variety of resources to connect HAF applicants with interpretation services, such 

as: 

o Montana Department of Transportation list of local interpreters, available 

here.

o Montana State University Extension program - Modern Language & 

Literatures Tutors and Translators website. 
SCOTT OSTERMAN GREG GIANFORTE

DIRECTOR GOVERNOR

COMMERCE.MT.GOV

301 S. PARK AVE. | PO BOX 200501 | HELENA, MT 59620-0501 | P: 406.841.2700 | F: 406.841.2701 | TDD: 406.841.2702

o Montana Language Services helps people connect and access 

interpretation services online. 

These are all resources available to NeighborWorks Montana housing 

counselors and can be leveraged by state of Montana to support borrowers

applying for the HAF program. 

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

We will partner with the Tribal housing authorities on the seven Indian 

Reservations located in the state to ensure they are aware of the statewide HAF 

program, particularly if they did not apply of their own allocation of funds. We 

will also work with the Council on Aging to ensure Montana seniors are informed 

about the HAF program, as well as the state Department of Public Health and 

Human Services Aging and Disability Resource Center.

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. 

Of Montana’s over 311,000 owner occupied housing units, the majority (93%) 

of owners are white (not Hispanic or Latino) and 88% are white-only and of 

no other race. Montana has an estimated 36,740 non-white homeowners. Of 

the 56 counties in the state, eight have a share of non-white homeowners 

higher than the 12% state average. In seven counties, half of all homeowners 

are non-white. These include Big Horn (49%), Blaine (35%), Glacier (58%), 

Hill (13%), Lake (18%), Petroleum (16%), Roosevelt (43%), and Rosebud 

(23%).

To identify counties that will be prioritized for outreach, Montana Housing 

defined target geographic areas as any county that is in the 75th percentile 

or higher in overall rank or in any of the following three sub-indices: social 

disadvantaged; housing cost burden; and, economic distress. There was 

significant overlap in the counties represented in the top 25 of the subindices and in the overall ranking. We are proposing to target marketing and 

outreach efforts to the top 10 counties in overall ranking, and the top 3 

counties in each category (social disadvantaged, housing cost burden and 

economic distress). This would include 24 counties in total (Big Horn, 

Blaine, Carbon, Cascade, Chouteau, Dawson, Flathead, Glacier, Hill, Lake, 

Madison, McCone, Missoula, Musselshell, Park, Phillips, Pondera, Ravalli, 

Richland, Rosebud, Roosevelt, Sanders, Treasure, and Wheatland). 

Performance Goals 

• Please explain how you intend to communicate your progress towards 

performance to the public. 
SCOTT OSTERMAN GREG GIANFORTE

DIRECTOR GOVERNOR

COMMERCE.MT.GOV

301 S. PARK AVE. | PO BOX 200501 | HELENA, MT 59620-0501 | P: 406.841.2700 | F: 406.841.2701 | TDD: 406.841.2702

Similar to our Emergency Rental Assistance program, we will report HAF 

process on our public-facing ARPA Dashboard - Funds Distributed through the 

State of Montana transparency website. This website is updated weekly with all 

ARPA related programs. 

We have HAF program web content available now, including searchable FAQs, 

at ARPA.MT.GOV/HOUSING. Program updates and customer testimonials will 

be shared via the Montana Housing Facebook page. Other means of 

communication include press releases for key milestones or programmatic 

changes, Gov Delivery emails to stakeholders and the Montana Housing 

electronic newsletter. 

Regular program updates, including applications received and number of 

households approved for funds, will be provided to the Economic Transformation 

and Stabilization and Workforce Development Advisory Commission, established 

under state of Montana House Bill 632. This advisory commission includes six 

elected officials and three appointees from the executive branch. Meetings are 

open to the public (in person and virtual), as well as live streamed via the state 

of Montana legislative website. Meetings are also recorded. 

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

success of your program. 

o Number of households assisted (align with Data Element #1: The total 

number of unique Homeowners that received HAF assistance of any 

kind).

o Number of foreclosures prevented (align with Data Element #5: The 

number of Delinquencies that were resolved with monetary HAF 

assistance).

o Number of utility shutoffs prevented (align with Data Element 7b: The 

number of Homeowners whose mortgage, insurance, taxes, utilities, or 

other qualified expenses related to housing were fully or partially paid, 

disaggregated by Payment Assistance Utilities). 

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

gender, etc. 

The application process will allow us to report disaggregate metrics by income, 

race, ethnicity, and gender. We are presuming Treasury will include the same 

race, ethnicity, and gender categories established for the ERA program in 

forthcoming HAF Reporting Guidance and are designing our program with that 

assumption. 

• 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. 

Prior to December 13 release of HAF Interim Reporting Guidance, our draft 

response stated: “We will take this additional metric under advisement, subject 
SCOTT OSTERMAN GREG GIANFORTE

DIRECTOR GOVERNOR

COMMERCE.MT.GOV

301 S. PARK AVE. | PO BOX 200501 | HELENA, MT 59620-0501 | P: 406.841.2700 | F: 406.841.2701 | TDD: 406.841.2702

to mutually agreeable contract terms with identified counseling and legal 

services providers. We have previously included various performance metrics 

within contracts with both the NeighborWorks Montana and Montana Legal 

Services Association.” However, it appears this metric is included in the Interim 

Report Guidance as required data element #5. We will ensure future contracts 

established with NWMT and MLSA using HAF will include this required data 

element to align with HAF Interim Reporting Guidance. 

Readiness 

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

readiness, including staffing, contractors, etc.... 

We hired and onboarded two new staff for our HAF program in mid-November

and already executed a contract with our software developer (ServiceNow) to 

design and build the online application, back office processing and payment 

interface system for the statewide HAF program. Our pilot program for Montana 

Board of Housing borrowers will use our in-house mortgage servicing software 

and will launch in the next 30 – 45 days. 

We are currently utilizing our ServiceNow software vendors to incorporate cocurrent administration of ERA2 within our ERA system. While we had hoped to 

launch our HAF program earlier this winter, we are working to prioritize multiple 

COVID-19 relief programs provided under the CARES Act, Consolidated 

Appropriations Act and the American Rescue Plan Act. Our scope of work for 

HAF software development will begin following completion of our ERA2 scope, 

which is estimated to conclude in about 4 weeks. 

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

you be ready to launch following approval? 

Our pilot program will launch in the next 30 – 45 days. We are striving to launch 

the full statewide program by May 1, 2022. We have been hesitant to expend 

administrative funds for software development and personnel to develop our 

HAF system absent Treasury approval of our HAF Plan and complete Treasury 

Reporting and Compliance guidance. Pending Treasury approval and release of 

HAF Reporting Guidance (Interim Reporting Guidance released December 13), 

we will launch our software development phase in January 2022. The 

development scope is estimated to be 14-16 weeks. As noted above, we have 

already executed a contract for software development, using the same 

ServiceNow vendor as employed for our ERA software solution. We are also 

leveraging as much from our ERA system as possible to reduce development 

time and costs.

• 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. 
SCOTT OSTERMAN GREG GIANFORTE

DIRECTOR GOVERNOR

COMMERCE.MT.GOV

301 S. PARK AVE. | PO BOX 200501 | HELENA, MT 59620-0501 | P: 406.841.2700 | F: 406.841.2701 | TDD: 406.841.2702

We submitted our pilot program budget to the state of Montana budget office 

and have received budget authority to begin expending the 10% initial payment 

received. 

We onboarded two new staff in mid-November, including a HAF Program 

Supervisor and HAF Application reviewer. 

We are in the process of finalizing the pilot program application and intend to 

launch the pilot program by providing the HAF application (paper version) to 

potentially eligible Montana Board of Housing borrowers in the next 30 – 45 

days. 

Budget 

• Your total allocation amount is $50,000,000.00 Our records indicate that you 

have received an initial 10% payment of $5,000,000.00 and that upon plan 

approval, you may draw up to $45,000,000.00 

o The total budget in your draft HAF plan is for $43,547,610.00. 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. 

The submitted budget was incorrect and did not include the pilot program 

budget that was prepared for the initial 10% payment. The budget has 

been amended to include the entire $50,000,000 allocation. We did 

include increases to Payment Assistance for Homeowners Utilities, adjust 

software document retention fees to reflect life of program (initial 

submission was annual cost), and an increase in document prep fees for 

recording and title based on increased costs for these services. 

o Under HAF guidance, Counseling and Legal Services Expenses may not 

exceed 5% of the funding received by the HAF participant. Under the 

amount currently budgeted in your plan, $43,547,610, the 5% cap would 

be $2,178,180.50. Therefore, the Counseling and Legal Services 

Expense budget of $2,500,000 would exceed the program cap by 

$321,819.50. Please revise your total budget or the amount allocated to 

Counseling and Legal Services Expenses to reflect the maximum 

allocation amount. 

The budget has been amended to include the entire $50,000,000 

allocation and includes $2,500,000 for counseling and legal services -

$1.25 million for each - which represents the 5% program cap for these 

services.