HAFP‐0106‐Arizona 

ADOH RESPONSE for Resubmission of Plan to Treasury 

 

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:

 No questions

Homeowner Needs and Community Engagement 

Data 

 

 Please explain how the program expects to serve targeted populations without more specific underlying

data.

See HAF Plan PAGE 4 for additional information about data sources. 

Response: ADOH is using census tract information to identify high minority communities and the

“Mortgage Nonpayments by State” tool on the website for the Federal Reserve Bank of Atlanta:  

https://www.atlantafed.org/center‐for‐housing‐and‐policy/data‐and‐tools/mortgage‐analytics‐and‐

performance‐dashboard to identify counties with high delinquency rates.  Paid marketing and outreach

efforts will be specific to those communities and will be language and culturally appropriate. In addition, 

local electric utilities, local jurisdictions and associations, as well as contracted Housing Counseling and

Community Action Agencies have all agreed to provide outreach to communities with high delinquency

rates, high minority populations, and low‐income households in Arizona’s small towns and rural 

communities. 

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

See HAF Plan PAGES 13 and 14 

Response:  

Based on the data available, targeting and outreach will focus on low income and high minority

communities as well as areas with high mortgage delinquency rates. In addition to direct paid marketing

based on a local PR firm’s research on Arizona’s low income and high minority communities (Pages 13 and

14), ADOH will  collaborate with local media, Community Action Organizations, Housing Counseling

Agencies, and other local jurisdiction organizations to focus on reaching the targeted populations

identified in the plan. Local resources like this will be key to reaching the targeted populations based on

their acceptance in the community, hands‐on experience, cultural knowledge, and trusted services.  

Community Engagement and Public Participation 

 

 In your plan submission, in response to the question asking whether you requested and received  input

from providers of housing counseling or legal services, you have indicated you did not. Please confirm this

is correct and, if so, please explain why you believe the HAF Plan would not be meaningfully informed by

input from housing counseling agencies.

Response: This is not correct. ADOH has corrected the response on Treasury’s portal for HAF Plan

submission.

 Your plan notes public input and community engagement in the plan development process. Please

explain how community engagement informed your plan’s programmatic and outreach  design.

See HAF Plan PAGE 5 / 6 

Response: Public input during the plan development process was used to modify our outreach and

marketing strategy, expand our accommodations for applications, identify reports and data needed by

our partners, and inform the process of intake and exploration of loss mitigation strategies. Some of the

questions that prompted clarification or additions to the draft plan are noted in the HAF Plan

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

Response: ADOH is communicating with a consultant for local Tribes about Arizona’s HAF plan and

implementation strategies so the consultant can help guide the Tribes in creating their program.   

 Please provide an update indicating any public comments you have received since you submitted your

HAF Plan, from which organization you received any such comment, and  whether you have responded to

the comments.

See HAF Plan PAGE 7 / 8 

Response: There were 35 questions that were directly addressed and publically posted.  These questions

and responses provided insight to the proposed program components, funding allocations to rural

communities, as well as requests for clarification on sections of the posted draft 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.

See HAF Plan Page 8

Response: The homeowner needs in Arizona, just for mortgage delinquency alone, greatly exceed the

amount of HAF funding allocated. However, jobs are coming back and unemployment numbers are

dropping, so homeowners have a brighter outlook for their future financial stability.  With this in mind,

ADOH used its experience with the HHF program as well as the State’s recent experience with Emergency

Rental Assistance to design a program that will be easy to apply for, prevent foreclosures, prevent utility

shut‐offs, and place the homeowners in a solid financial position.  HAF funding will be used for

Reinstatement, Utility/Internet, Monthly Mortgage, Delinquent Property Tax, Association Fee/Lien

assistance, Housing Counseling, and application assistance.  Budgets for each program were based on

bank reported average mortgage delinquencies and the State’s experience with average utility

delinquencies in the Rental Assistance Program.  These were combined to arrive at a maximum assistance

amount per household and a maximum monthly assistance amount for fraud prevention.  To expand the

reach of HAF, agencies assisting with HAF applicants are encouraged to review all mortgage loss

mitigation options prior to the client applying for HAF.   

 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)?

See HAF Plan PAGE 10 / 11 

Response:  Applicants who consult with a contracted Housing Counseling Agency will participate in a

comprehensive intake process to determine immediate needs and any loss mitigation assistance that can

be applied prior to HAF. Those agencies have partnerships and service contract that enables them to

reach out directly to the servicer to stop a foreclosure process and notify of the HAF application.  Other

threats such as utility disconnection, tax delinquencies, HOA liens, etc. can be flagged in the system by

the Agency assisting the applicant and also by an Adjudicator who reviews the application and

documentation.   

   
 Please confirm your exclusion of reverse mortgages and explain what steps you have taken to assess the

needs of homeowners with reverse mortgages. Please summarize any community feedback or data on

which you have based this decision. To the extent, reverse mortgage borrowers are eligible under any

program, please adjust your plan to reflect that they are included and explain any limitations that will

apply to these borrowers.  

See HAF Plan PAGE 8 / 9 & Term Sheet (Delinquent Property Tax (DPT) Payment Assistance) 

Response: There has been an addition to an eligible mortgage type where Reverse Mortgages (secured by

real estate or a dwelling / permanently affixed to real property and taxed as real estate) is added as an

eligible mortgage type. A Reverse Mortgage may be brought current for property charges, which include,

property taxes, homeowners hazard insurance premiums, flood insurance premiums, condominium fees,

and homeowners’ association fees. 

 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.

See HAF Plan PAGE 10

o The role housing counseling or legal services providers will play in supporting  homeowners’

efforts at engaging in loss mitigation.

See HAF Plan PAGE 10

   

 In situations where the HAF assistance includes or will be limited to payments for mortgage  

reinstatement, please explain whether and how your will assess whether a similar or more appropriate

alternative loss mitigation option is available through the servicer.

See HAF Plan PAGE 10 

Response: Through the HCA standard intake processes and evaluation, an eligible applicant will be able to

explore loss mitigation options prior to making application for HAF funding.    If the applicant submits on

their own, Adjudicators who review the application and documentation will contact the mortgage servicer

to see if loss mitigation is an option for the applicant prior to approving HAF payment to reinstate the

mortgage. 

 How will your program leverage resources available through a loss mitigation process to benefit  eligible

homeowners and how will your program avoid using HAF funds in ways that duplicate relief that available

loss mitigation options might provide?

See HAF Plan PAGE 10 

Response: Through the HCA standard intake processes and evaluation, an eligible applicant will be able to

explore loss mitigation options prior to making application for HAF funding.  If the applicant submits on

their own, Adjudicators who review the application and documentation will contact the mortgage servicer

to see if loss mitigation is an option for the applicant prior to approving HAF payment to reinstate the

mortgage. 

Regarding utility payments, adjudicators will contact utilities directly to verify amounts past due prior to

authorizing payment.  Additionally, ADOH will continue to collaborate with other State departments, DES

and AHCCCS, to coordinate and leverage assistance as well as reduce the opportunity for duplication and

fraud. 

 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?

See HAF Plan PAGE 10 

Response: ADOH has contracted  with Housing Counseling Agencies and through their standard intake

process for homeowner counseling services; they will  have the opportunity to evaluate whether an

applicant would have potential to secure a sustainable monthly payment after HAF‐has paid for

delinquency resolution.
 Are you anticipating increased winter home energy costs and their potential impact on the homeowners

that HAF will serve?

Response: No, Arizona does not typically experience extremely cold temperatures that cause excessive

winter energy costs.  At this time, we anticipate that HAF utility payments will prevent disconnections

associated with unpaid, higher electricity costs experienced over the summer months in the extreme heat

of our desert regions.  

Eligibility 

 

 Your plan refers to “Arizona AMI”, please note that under the HAF guidance, eligibility is determined

based on the household’s address and may be different in different parts of thestate. Please refer to the

look‐up tool published by the Department of Housing and Urban Development for specific limits at the

county or MSA level.

Response: “Arizona AMI” has been removed from the plan – the data collected and being used is from the

look‐up table published by HUD for specific limits at the county level and is referenced as such on the

application portal. 

 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 Homeowners in active bankruptcy may be ineligible

See HAF Plan PAGE 12 

Response: After reevaluation, ADOH has changed the plan to reflect, “Homeowners in active

bankrupt may be eligible.  

o Homeowners who previously filed for bankruptcy but are no longer in bankruptcy must provide

proof of court ordered “discharge” or “dismissal”

See HAF Plan PAGE 12 

Response: They will be encouraged to provide proof of court ordered “discharge” or “dismissal.”

In addition to this, waivers and/or exceptions may be provided to accommodate extenuating

circumstances, such as disabilities, practical challenges related to the pandemic, or a lack of

technological access by homeowners if such documents are inaccessible.

 Please provide the rationale for not using a fact‐specific proxy as one method for establishing eligibility

under your plan, including how you determined that without such a proxy, your program can avoid

unnecessary barriers to participation by eligible homeowners.

See HAF Plan PAGE 11 

Response: The application portal designates priority levels for attested household incomes during the

application process and performs a fact‐specific proxy for household income, providing households below

100% of AMI high priority for adjudication and those households at 150% low priority. 

 Your programs set $25,000 as the maximum amount of 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?

See HAF Plan PAGE 8 

Response: The $25,000 per household amount was based on a 12‐month average mortgage payment

($1,300) for mortgage reinstatement, 12 months of delinquent utilities, and 3 months of mortgage

payments going forward. This estimate is consistent with one of our largest lenders reporting an average

of 9 months delinquent and $11,000 in arrears per household as of August 2021.

   
 

Outreach 

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

English proficiency.

See HAF Plan PAGE 13 for marketing, targeting, and outreach details. 

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

See HAF Plan PAGE 13/14 

 

Prioritization 

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

program prioritize Socially Disadvantaged Individuals?

See HAF Plan PAGE 11 

Response: The application portal designates priority levels for attested household incomes during the

application process and performs a fact‐specific proxy for household income, providing households below

100% of AMI high priority for adjudication and those households at 150% low priority.  HAF payments by

income levels and racial demographics will be closely monitored and adjustments may be made in the

future to further target these households by revising thresholds.  

Performance Goals 

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

See HAF Plan PAGE 16 

Response: ADOH plans to communicate its performance to the public by publishing a real‐time dashboard

on its application portal as well as on the Department’s website.  

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

See HAF Plan PAGE 17 

Response:  

 Number of home losses prevented

 Number of utility disconnections prevented  

 Percentage of total assistance provided to low income (<= 100% AMI) minority households

 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.

See HAF Plan PAGE 16 

Response: ADOH added the number of home losses prevented via other loss mitigation measures without

the use of HAF assistance funds to its performance metrics.

Readiness 

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

contractors, etc.

See HAF Plan PAGE 18 

Response: ADOH is ready for program launch. Application portal launched on November 1, 2021 and has

received 1647 submitted applications to date.

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

following approval?

See HAF Plan PAGE 18‐21 

Response: ADOH is ready for immediate full program launch. A pilot application portal was launched on

November 1, 2021 and has received 1647 submitted applications to date.

   
 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 ormade available to

homeowners.

See HAF Plan PAGE 21 

Response: To date ADOH has drawn down a total of $4,480,432.97 of the initial 10% payment disbursed

to the Department and holds a balance of $15,218,000.93. 

Budget 

 Please confirm that you will not be allocating any funds to housing counseling or legal services.If so,

please explain your rationale for not doing so.

See HAF Plan PAGE 21 

Response: ADOH has allocated $2 million to housing counseling services. These partnerships will provide

additional options and opportunities for homeowners who require assistance filling out and submitting

applications while also directly targeting and serving vulnerable populations through outreach events in

local communities.

 Your budget indicates $2.5 Million for Displacement Prevention Assistance Payment – a program which

you are considering. Please note that Treasury will not approve funds for a program design element

without your providing a description of the program, including term sheets, sufficient to confirm that the

program is permissible under HAF guidelines. You may request apartial amount of your total allocation

and submit a plan for the remainder or a portion of theremainder at a later time.

See HAF Plan PAGE 21 

Response: ADOH has removed the funding set aside for Displacement Prevention Assistance and

reallocated it under Monthly Mortgage Assistance.  At this time, ADOH anticipates utilizing all available

funding for the prevention of foreclosures and utility disconnections.  ADOH will reconsider the inclusion

of Displacement Prevention Assistance after twelve months of experience with the current HAF Program.