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HAFP---0058 Indiana Housing and Community Development

Treasury Feedback for Resubmission of Plan

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

Completeness

• Your plan lists Chris Nevels as the Authorized Official, while the original application for HAF

payments was signed by Jacob Sipe. 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.

Changed to Jacob Sipe.

Homeowner Needs and Community Engagement

Data

• No questions.

Community Engagement and Public Participation

• Your plan does not clearly indicate what organizations were engaged in program design, other

than the Indiana Foreclosure Prevention Network, that represent populations which are low and

moderate income or have been affected by historic housing discrimination. Please explain how

the program is confident in its ability to reach targeted populations without engaging such

organizations in planning and implementation or identify what groups were involved in the

program design

The Indiana Foreclosure Prevention Network is comprised of the following partners: 

• The Affordable Housing Corporation of Marion, Indiana 

• City of Gary Department of Community Development 

• City of South Bend 

• Community Action Program of Evansville and Vanderburgh County 

• Dubois-Pike-Warrick Economic Opportunity Committee 

• HomesteadCS

• HOPE of Evansville, Inc. 

• Neighborhood Christian Legal Clinic 

• Northwest Indiana Reinvestment Alliance 

• Transition Resources Corporation 

These organizations represent a broad coalition of entities dedicated to serving low- and moderateincome populations. The Network includes local governments, housing counseling agencies, legal service 

providers, and community action agencies that assist individuals across the entire state of Indiana in 

urban, suburban, and rural communities. Services offered by these agencies include housing counseling, 

affordable housing development, community development, home repairs, individual development 
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accounts, energy assistance, weatherization, food banks, and educational services. These programs all 

target populations that are traditionally low- and moderate-income and that have been impacted by 

housing discrimination. Although the IFPN was listed as a single organization it is important to remember 

that it is comprised of ten distinct organizations that each bring its own history and knowledge of serving 

vulnerable populations to IHCDA’s HAF program. IHCDA fully intends to utilize this knowledge, as well as 

IHCDA’s own experience running similar programs, to inform its program design and outreach strategies.

• 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.

IHCDA continues to collaborate with IFPN and other partners to ensure its program design and 

outreach strategy is as seamless and effective as possible. For example, in discussing IHCDA’s initial 

program design with the IFPN, agencies expressed concern regarding the level of housing counseling 

that would be provided to applicants. As a result of this feedback, IHCDA has revised its program design 

to more fully incorporate housing counseling into the application process and to ensure that any 

applicant that wishes to speak to a housing counselor can do so at no cost to the homeowner. 

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

There are two tribes that have land in Indiana. The Pokagon Band of Potawatomi received land near South 

Bend, Indiana. The Miami Tribe of Oklahoma has land located in Fort Wayne, Indiana. The IFPN includes

organizations that provide services in these areas of the state and IHCDA can utilize these groups to 

conduct outreach and coordinate with each tribe.

• 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.

IHCDA has received no new public comments since submitting its HAF Plan. 

Ongoing Assessment of Homeowner Need

• No questions.
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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.

In order to identify the areas of the state in greatest need, IHCDA developed a ranking method that 

incorporated data for all 92 counties. IHCDA categorized these metrics into four indicators: Eligible 

Homeowners, Socially Disadvantaged Individuals, Economic Distress, and Housing Distress.

IHCDA recognizes that the four indicators should have varying degrees of influence on the final ranking 

of the counties. Weights were chosen so that SDI would have the greatest influence, followed by Eligible 

Homeowners, Housing Distress, and Economic Distress. The resulting weighted value represents each 

county’s overall ranking. These higher-ranking counties will be further evaluated as potential 

beneficiaries for this program and will be selectively targeted as part of IHCDA’s marketing and outreach 

plan. 

For additional information, see pages 2-8 of the attached draft HAF policy. Please note this policy is an 

early draft and has not been updated to reflect subsequent Treasury guidance. This document will be 

updated once final Treasury approval is received.

• 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)?

As part of IHCDA’s HAF application procedure, applicants will be able to select whether they wish to 

receive free housing counseling assistance. Any applicant who chooses to request assistance will be 

assigned to a housing counselor employed by an IFPN agency. That counselor will engage with the 

household to determine if the household is in crisis and what the most effective form of assistance may 

be, including, but not limited to, HAF. IHCDA and IFPN will also work collaboratively to identify several

“red flags” in applications that indicate the homeowner is in crisis. IHCDA’s software system will identify 

applicants with these “red flags” and automatically assign them to IFPN counselors. IFPN counselors will 

review these applications and will be able to provide additional assistance if needed or requested. 

As part of the counseling process, every IFPN housing counselor will assess the homeowner’s specific 

situation including a determination of whether the homeowner has needs that need to be addressed 

under an expedited timeline. 

• Please confirm your exclusion of second mortgages, reverse mortgages, and contracts for deeds

and explain what steps you have taken to assess the needs of homeowners with these types of

mortgages. Please summarize any community feedback or data on which you have based this

decision.

IHCDA’s policies on these items are informed by best practices learned while administering the Hardest 

Hit Fund. It has been IHCDA’s experience that most lenders do not foreclose on second mortgages and 

the payments on these mortgages are minimal compared to first mortgages. Reverse mortgages do not 

have a required payment – however, ICHDA will pay delinquent HOI, tax, or HOA payments for those 

homeowners. Finally, IHCDA requires a lien be placed on assisted properties. Because this is not possible 
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for a land contract, they are ineligible for assistance. These policies were all designed based upon years 

of data and experience obtained through HHF. 

• 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.

Housing counselors will be utilized by IHCDA’s HAF program in multiple ways. IHCDA is 

currently using its IFPN network to contact homeowners who have signed up on IHCDA’s 

website to be notified when HAF launches. Counselors will provide an update on HAF and 

offer counseling free-of-charge to these individuals. If a homeowner is interested in pursuing 

non-HAF assistance, IFPN counselors will conduct an assessment and help put the 

homeowner in contact with their servicer or lender to work out a solution. In doing so, IHCDA

hopes to identify as many potential HAF applicants as possible for whom other loss mitigation 

options may be preferable. If the homeowner instead wishes to continue waiting on HAF, the 

counselor will take down the homeowner’s contact information and will reach back out to 

them once the HAF program opens. This will allow IHCDA to filter through the initial HAF 

waitlist, with thousands of names, and identify homeowners who are still interested in the 

program. When HAF launches, they will be contacted by a housing counselor with whom they 

already have an established relationship. As a result, IHCDA’s HAF program will begin 

operations more efficiently and IHCDA can provide better and more personalized service to 

applicants. All counseling conducted prior to the launch of HAF will be paid for using state 

funding that has been earmarked for IFPN. 

Once HAF is launched, housing counselors will be an integral component of the application 

process. When applicants start their applications, they will be asked if they would like to 

receive free housing counseling. If an applicant selects “Yes” they will be assigned to an IFPN 

housing counselor who will work with them throughout the application process. This can 

include basic assistance like ensuring the applicant is submitting correct documentation. 

However, housing counselors will be encouraged to conduct a complete review of the 

homeowner’s current situation to determine what approach may best serve the applicant. 

This may be HAF, or it may be alternative loss mitigation options. Housing counselors will 

have the freedom to assist the applicant in the manner they feel is best. This strategy allows 

IHCDA to provide free one-on-one counseling to applicants who are in need but also allows 

applicants who are not in need of counseling to proceed through the process and have their 

application assigned to reviewers that are not housing counselors. This ensures IHCDA‘s 

review process can proceed quickly and efficiently while simultaneously providing 

personalized assistance to those most in need. 

Although IHCDA anticipates that the system described above will function smoothly,

discussions with IFPN agencies made it clear that there will be applicants who may not know 

they need housing counseling assistance or who refuse to request it for one reason or 

another. To capture these individuals, IHCDA, in consultation with IFPN, will identify data 
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points that it considers “red flags”. If a certain number of these “red flags” are identified in an 

application, IHCDA’s application software system will automatically assign the file to an IFPN 

housing counselor. Additionally, if an applicant who indicated they are not in need of housing 

counseling changes their mind, the reviewer currently assigned to the homeowner can 

transfer the file to an IFPN counselor who can then provide additional assistance. 

IHCDA’s application software system can also flag incomplete applications. After a to-bedetermined amount of time has passed, incomplete applications will be assigned to IFPN 

counselors. Counselors will be responsible for reaching out to these applicants to see if they 

need assistance in completing their application or if they are no longer interested in applying. 

This will allow IHCDA to help applicants who may be having difficulties completing their 

application because they are not comfortable with the online system while simultaneously 

removing applications from individuals who are no longer interested in the program.

Finally, applicants who receive monthly payments will be strongly encouraged to meet with a 

housing counselor on a continuing basis while they are being assisted. Homeowners receiving 

monthly payments that also requested counseling during the application process will be able 

to stay with the counselor that assisted them. Homeowners receiving monthly payments that 

did not request counseling assistance during the application process will be assigned an IFPN 

counselor. 

• 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?

IHCDA will heavily involve housing counselors in the application process. These counselors will use their 

expertise and years of experience to identify homeowners for whom non-HAF loss mitigation options are 

a better fit. Housing counselors will have the authority to advise homeowners of other options available 

to them and homeowners will be free to withdraw their HAF-application and pursue other assistance 

options. They will still be able to work with their housing counselor if they choose to do so. By utilizing 

the extensive knowledge base of its IFPN agencies, IHCDA can identify, on a case-by-case basis, which 

homeowners are a good fit for HAF and which homeowners would be better served discussing other loss 

mitigation options with their servicer or lender. 

• 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?

IHCDA will heavily involve housing counselors in the application process. IFPN counselors are HUDcertified and trained to assist homeowners in making such determinations. Additionally, homeowners 

receiving monthly HAF assistance will be encouraged to maintain a relationship with a housing counselor

while they continue to receive assistance. By offering ongoing housing counseling assistance, IHCDA 

hopes to identify and address any potential issues for homeowners before they become serious enough 

to threaten the homeowner’s housing stability. 
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• Are you anticipating increased winter home energy costs and their potential impact on the

homeowners that HAF will serve?

IHCDA will closely monitor relevant data on utility costs and work in partnership with utility 

companies and its own energy assistance and weatherization programs to ensure it remains aware 

of potential cost increases and the impact that could have on homeowners. IHCDA remains open to 

modifying its policies and procedures to address issues that could arise because of rising energy 

costs and has discussed adding utility assistance to its HAF program once the program stabilizes 

following the initial launch phase.

• Your programs set $35,0000 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?

The maximum amount of assistance for HAF was determined using historical data obtained through 

IHCDA’s Hardest Hit Fund (HHF) program. IHCDA administered the HHF program for over ten years.

The maximum amount of assistance available to homeowners in the HHF program was $30,000.

Overall, the median assistance per borrower in HHF was $13,512.77. On occasion there were 

homeowners with reinstatement amounts that slightly exceeded $30,000. Therefore, IHCDA 

increased the maximum assistance amount to $35,000. IHCDA is confident this amount will be more 

than sufficient for homeowners across the state. 

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 The requirement for Mortgage Reinstatement that the homeowner’s front-end housing

debt-to-income ratio not exceed 38%. (Please explain how your program will make this

determination for each homeowner.)

This requirement was determined using industry standards and historical data obtained through IHCDA’s 

Hardest Hit Fund program. Over the course of HHF the DTI ratio underwent slight adjustments based on 

reviews of program data until being finalized at 38%. IHCDA’s successful record of distributing HHF funds 

indicates this ratio was appropriate for the program. IHCDA intends to model HAF on its HHF program and 

therefore plans to use the same DTI ratio. During HHF, this ratio was determined using applicant pay stubs.

IHCDA will use similar methods to determine this ratio for HAF and anticipates that its application software 

will be able to easily calculate and track this ratio using information and documentation submitted by the 

applicant. IHCDA can easily access and track metrics and data to determine if changes to the ratio are 

needed. 
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o That homeowners who are no longer in bankruptcy provide proof of court ordered

“discharge” or “dismissal”.

This requirement mirrors the policy established for IHCDA’s Hardest Hit Fund. In HHF, most lenders 

would not accept funds if the homeowner was in an active bankruptcy. Lenders would require the 

bankruptcy be discharged and proof of dismissal be submitted before moving forward with the 

homeowner. Therefore, IHCDA requires this documentation be provided at the time of application 

to avoid unnecessary back and forth between lenders, applicants, and IHCDA. IHCDA is willing to 

consider modifications to this policy if it becomes apparent lenders have changed their stance on 

this requirement.

• 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 a proxy, your

program can avoid unnecessary barriers to participation by eligible homeowners.

IHCDA is confident it will be able to provide a smooth and easy application process for homeowners 

even without utilizing a fact-specific proxy for establishing eligibility. IHCDA’s years of experience 

administering the HHF program have provided it with a wealth of knowledge related to best 

practices for operating programs of this size and scope. Although IHCDA is still requiring some 

documentation as part of the application process, it has reduced the amount required as compared 

to HHF and has also allowed applicants to self-attest to some program requirements rather than 

requiring the submission of onerous documentation. IFPN housing counselors will also be available to 

provide personal assistance to anyone experiencing difficulties in applying. IHCDA also made it a 

priority to partner with a vendor that could provide a modern, streamlined application software for 

HAF. This software will provide an easy, uncomplicated application experience to homeowners. 

Applicants will be able to apply using their computers or phone (non-electronic applications will be 

accepted as well) and will be able to stop and resume their application later without losing their 

place. This software will also make it easy for IHCDA to identify and resolve issues that are creating 

complications for applicants by reviewing reports and data to identify bottlenecks in the process. If 

necessary, IHCDA is willing to make policy and process adjustments to improve the experience for 

homeowners across the state.

Outreach

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

limited English proficiency.

IHCDA has cultivated relationships with a diverse public and private network of groups that serve 

minority communities statewide. IHCDA is also planning to market to traditionally under-served 

and at-risk populations and the community leaders, associations, and media

markets/radio/papers they serve. This includes organizations like The Indianapolis Recorder, 
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Urban League, LaPlaza, Damien Center, Indy Pride, Mexican Consulate, Indiana Commission on 

Hispanic and Latino Affairs, Burmese American Community Institute, and Indiana Black 

Expo. IHCDA’s call center is bilingual, and we will utilize a universal translation line for languages 

outside of English/Spanish.

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

IHCDA will work with its network partners to provide bilingual information to culturally relevant 

entities statewide. IHCDA will also assist in informational meetings and public events as 

necessary. This includes events such as Latin Fest, Black Expo, and Indy Pride.

Prioritization

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

your program prioritize Socially Disadvantaged Individuals?

IHCDA does not intend to serve households who are over the income eligibility limits established in the 

HAF guidance. To be eligible to receive HAF funding, homeowners must have incomes equal to or less 

than 150% of the Area Median Income, adjusted for household size, or 100% of the Median Income for 

the United States, whichever is greater.

Regardless, IHCDA does have a method for identifying areas of the state with a high percentage of 

Socially Disadvantaged Individuals. IHCDA developed a ranking method that incorporated data for all 92 

counties. IHCDA categorized these metrics into four indicators: Eligible Homeowners, Socially 

Disadvantaged Individuals, Economic Distress, and Housing Distress.

IHCDA recognizes that the four indicators should have varying degrees of influence on the final ranking 

of the counties. Weights were chosen so that SDI would have the greatest influence, followed by Eligible 

Homeowners, Housing Distress, and Economic Distress. The resulting weighted value represents each 

county’s overall ranking. These higher-ranking counties will be further evaluated as potential 

beneficiaries for this program and will selectively targeted as part of IHCDA’s marketing and outreach 

plan. 

For additional information, see pages 2-8 of the attached draft HAF policy. Please note this policy is an 

early draft and has not been updated to reflect subsequent Treasury guidance. This document will be 

updated once final Treasury approval is received.

Performance Goals

• Please provide any update to the preliminary performance goals you included in you plan.
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There have been no updates to IHCDA’s proposed performance goals since its plan was submitted. 

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

public.

IHCDA will host an online dashboard available to the public that will display important program 

metrics on a continually updated basis. This was one of the primary factors IHCDA considered when 

selecting a software vendor for HAF. IHCDA will also engage in public outreach and marketing and 

will continue to provide updates to and solicit feedback from homeowners, lenders, and other 

important community stakeholders. Updates about the program will be offered on a regular basis 

during IHCDA’s board meetings which are open to the public. Recordings of these meetings are

made available on the IHCDA website. Finally, IHCDA’s application software can be used to 

generate reports that can be distributed to the public via IHCDA newsletters, social media, and 

press releases. 

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

program.

1. Number of borrowers served per month / Application approval rate

2. Unique visits to application portal 

3. Number of households served in areas of highest need as determined by the Data & Needs 

Analysis

• 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.

IHCDA can include this as an additional metric and should be able to track this data point in conjunction 

with its IFPN housing counseling partners. 

Readiness

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

• staffing, contractors, etc.

IHCDA is in the process of finalizing its contract with a third-party vendor selected through an RFP 

process and anticipates being fully under contract soon. While waiting on contract approval, IHCDA has 

continued to informally work in partnership with this vendor on program design and process. IHCDA’s 

vendor is prepared to move forward with all of its subcontractors as soon as the final contract is 

executed. The vendor has a team of case managers ready for onboarding as well and is prepared to 

begin training as soon as possible.
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IHCDA continues to engage in discussions with the agencies that comprise the IFPN and expects to be 

able to quickly integrate them into the HAF program once it launches. Finally, IHCDA staff have also been 

deeply involved in the HAF design process and should be prepared to work in partnership with our 

vendor as soon as approval is received. 

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

launch following approval?

IHCDA anticipates being able to launch its HAF program within thirty days of Treasury approval if not 

sooner. Once IHCDA has a target start date, its third-party vendor can immediately engage its

communications subcontractor and begin an informational, statewide campaign to publicize the program 

and its requirements. 

• 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.

IHCDA has not spent any of its initial 10% allocation and is not currently operating a pilot program. 

Budget

No Questions