HAFP‐0082‐ Arkansas Development Finance Authority 

Treasury Feedback for Resubmission of Plan 

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

Completeness 

 Your plan lists Robert Arrington as the Authorized Official, while the original application for 

HAF payments was signed by Governor Asa Hutchison. 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. 

 ADFA plans to establish a new authorized representative for HAF payments and will be 

submitting a request to the email above with further details.  

Homeowner Needs and Community Engagement Data 

 No questions 

Community Engagement and Public Participation 

 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 

 ADFA confirms we have not received any additional public comments on the content of 

the plan since the original plan submission date.  

Ongoing Assessment of Homeowner Need 

 No questions 

Program Design 

 Please confirm your exclusion of reverse mortgages and contracts for deed and explain 

what steps you have taken to assess the needs of homeowners with these mortgage types. 

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

decision. 

 ADFA confirms the exclusion of reverse mortgages and contracts for deed mortgage types in 

its initial HAF plan. It reserves the right to make changes at a later date based on need, as 

expressed by actual homeowner applications and/or receipt of public comment. At this time, 

ADFA has not received any public comment or community feedback on this item.  

 Please confirm that your program will not be utilizing housing counselors or legal 

services to assist homeowners in evaluating loss mitigation options available for their 

mortgage. If your program will not be utilizing housing counselors, describe how your 

program will assist homeowners in evaluating their loss mitigation options. 

 ADFA will engage a HUD‐approved housing counseling agency to assist homeowners in 

evaluating loss mitigation options available for their mortgage and accept referral from 
ADFA’s HAF program. The HCA will be compensated for these services.  

 ADFA will refer homeowners to housing counselors if either of the following conditions are 

met: 

• Homeowner indicates during the pre‐qualification survey (before an 

application is submitted) they are unable to resume mortgage 

payments – even if the loan was reinstated, and 

• The applicant is determined ineligible (after an application has been 

submitted) for assistance based on program criteria such as income 

>150% AMI, etc. 

 These homeowners will be directed to work with their servicer to explore alternative loss 

mitigation options, and referred for housing counseling assistance and support. The ADFA 

website and application portal will provide information about housing counseling agencies 

and legal services to inform applicants of resources throughout the state should they be 

needed by the applicant.  

 Homeowners who indicate during the pre‐qualification survey they are able to resume 

mortgage payments after reinstatement and who meet all program criteria will be fully 

reinstated.  

 ADFA takes seriously Treasury’s guidance to avoid documentation requirements that are 

likely to be barriers to participation for eligible households. Utilizing applicant responses to 

determine if the homeowner is best served by reinstatement or referral to their servicer, 

housing counseling and/or legal services will keep the program administratively simple and 

assessable.   

• On NCSHA’s recent call with Treasury and FHA, the approach to “ask 

the homeowner if they can resume payments” was highlighted 

numerous times as a simple way to determine if the homeowner 

requires additional assistance.  

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

mortgage  reinstatement, please explain whether and how you will assess whether a 

similar or more appropriate alternative loss mitigation option is available through the 

servicer. 

 Homeowners who meet ADFA’s HAF program criteria as described above will benefit 

from the immediate foreclosure relief and debt reduction associated with 

reinstatement of their past due mortgage payments. Debt reduction is particularly 

meaningful for low‐to‐moderate income households, especially those who reside in 

persistently impoverished counties and those who are socially disadvantaged. 

Reinstatement is a complement to, not a replacement of, many other loss mitigation 

options made available to homeowners from their servicer/investor.   

 Homeowners who advise ADFA they are unable to afford their current mortgage payment 

including those who advise they are unable to resume post‐assistance payments, even if 

their loan was reinstated, will be referred for housing counseling assistance. Doing so will 

enable these homeowners the opportunity  to explore additional loss mitigation options and 

receive support as they work with their loan servicer to achieve more affordable mortgage 

payment.  
 ADFA has identified a state‐run, HUD‐approved housing counseling agency (“HCA”) who can 

provide housing counseling support to these homeowners. This HCA has multiple offices 

throughout the state to provide services to ADFA’s referrals. ADFA will begin discussions 

with the HCA to develop a referral process that includes outcome reporting sufficient to 

meet Treasury’s HAF Interim Reporting Guidance.  

 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? 

 ADFA does not intend to develop a Program metric to define a sustainable mortgage payment 

or collect the documents needed to perform a comprehensive underwrite to calculate this 

metric for purpose of eligibility determination. ADFA believes it is the servicer’s responsibility to 

determine what type of relief assistance the homeowner will get based on the homeowner’s 

loan type, actual loan details, including the corresponding loss mitigation options available from 

the investor at the time of the review. We also believe that housing counseling and/or legal 

services are best positioned to provide homeowner support as they work with their servicers.  

 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? 

 ADFA determined this cap amount based on data available at the time of the original plan 

development. The pilot program has provided additional data and important insights. 

ADFA intends to increase the maximum amount of assistance to $40,000 per homeowner. 

ADFA does not want to prevent an otherwise eligible homeowner from receiving 

reinstatement assistance based solely on exceeding its program cap.  

• During the pilot, ADFA denied eight (8) homeowners for exceeding 

the program cap.  

• Increasing the program cap to $40,000 will ensure eligible 

homeowners with protracted delinquencies and hardships are able

to obtain much‐needed relief including those households in areas 

with higher housing costs.  

 In addition, ADFA intends on amending the number of delinquent mortgage payments 

required to apply for assistance from one to two payments. Doing so acknowledges that 

mortgage default begins once a homeowner misses two payments. This change ensures 

ADFA is mitigating true financial hardships associated with mortgage default that may lead 

to foreclosure.   

 To the extent your program will provide HAF funds when reinstatement amounts are in 

excess of the program cap, what steps will you take to ensure that the homeowner’s 

delinquency is resolved and the account is brought fully current? 

 ADFA believes that increasing the reinstatement cap to $40,000 will significantly mitigate or 

eliminate a partial reinstatement that requires use of homeowner funds to bring a loan fully 

current. ADFA does not want to decline an otherwise eligible homeowner from receiving 

reinstatement assistance based solely on the program cap. 

 ADFA intends to provide partial reinstatement assistance only when a homeowner has funds 

to pay the past due amount that exceeds the Program cap. We are currently working with 

servicers to ensure they will combine HAF and homeowner funds to bring the loan fully 
current.  

 To the fullest extent possible, ADFA will partner with servicers to maximize outreach efforts 

that enable homeowners to resolve their delinquency through the use of a HAF 

reinstatement. In addition, ADFA will look for opportunities to use HAF reinstatement 

assistance in conjunction with a servicer‐provided loan modification that results in a post‐

modified mortgage payment the homeowner confirms they can afford going forward.   

 Please provide the rationale for the requirement that the mortgage must be held 

by a lender/servicer with an NMLS number. Would this requirement risk the 

exclusion of homeowners in need of assistance? 

 ADFA requires use of an NMLS number for servicer participation as a fraud 

prevention method. Specifically, ADFA wants to avoid sending HAF monies to a 

private party that is not an established mortgage servicer. ADFA will monitor this 

element of the program and make adjustments to ensure homeowner applicants 

with servicers that do not have an NMLS number are not being excluded without 

consideration.  

 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. 

(1) Based on experience in the pilot program, ADFA now intends to implement a fact‐

specific proxy for the program. The approach will include written attestation plus 

reasonable fact‐specific proxy for household income. A written attestation as to 

household income will be provided by the homeowner, and the proxy will be used for 

the homeowner’s income verification. If the household falls within any of the persistent 

poverty counties identified, the household will be presumed to meet income 

verification requirements. Doing so will avoid unnecessary barriers to participation and 

ease the documentation burden for these socially‐disadvantaged homeowners. 

Outreach 

 No questions. 

Prioritization 

 Please discuss the rationale for limiting the prioritization of Socially Disadvantaged 

Individual (SDI) applicants to the first 30 days of the program. 

 The approach discussed within the plan submission is intended to facilitate an early 

advantage for SDI applicants. SDI and income targeted applications submitted within the 

first 30 days will receive priority processing and take precedence over other application in 

the pipeline. While the initial review may take longer than 30 days, it will be based on the 

submission date. Once the early advantage SDI applications have been reviewed, we will 

then begin actively monitoring the portfolio to manage priority. Through our pipeline 

management, we will ensure we meet the targeting goals and requirements set forth by US 

Treasury for both income targeting and the SDI population. We believe the approach noted 

within the plan allows the program to meet the prioritization requirements as well as ensure 
uninterrupted funding to applicants. 

Additionally, we will measure the success of the outreach and marketing and use 

our pipeline to help inform us of changes needed to ensure we’re reaching the SDI 

applicants and meeting the income targeting goals.  

 Given that SDI applicants may be more difficult to reach than other applicants, describe 

your strategy for conducting outreach to SDI applicants to ensure that they will be able to 

apply for assistance within the first 30 days of the program. 

 SDI applicants are a priority of Arkansas’s HAF program. We plan targeted outreach efforts to 

communicate with this population group. We have a two‐phased approach. Phase 1 is our 30‐day 

prioritization period to ensure SDI homeowners are aware of the program and encouraged to 

apply. Phase 2 is our ongoing SDI communication which will include elements of Phase 1 as well 

as continue to inform and educate these homeowners throughout the Program lifecycle. Our 

messages will serve to answer questions and remove obstacles that may hinder them from 

applying. Details related to the Phase 1 approach are listed below. The efforts in Phase 2 will be 

similar, but on an ongoing basis. As noted below in our Readiness section, we plan to begin the 

Phase 1 marketing campaign two weeks prior to a statewide go‐live date.  

• Phase 1: 30‐day SDI initial prioritization outreach

 Radio – we will create and place PSAs and paid radio spot on local stations 

that broadcast in these underserved markets. Our media buy will be a mix 

of stations with emphasis placed on stations whose listeners are in high‐

SDI communities as well as Spanish and Marshallese language stations. 

 Social media – Arkansas HAF will combine social media posts with paid 

social media ads. The ads will use social media algorithms to target zip 

codes with high SDI residents and areas identified by census tract data. 

Posts and paid ads will appear in English, Spanish, and Marshallese.   

 How‐to videos have been created that walk a homeowner through a step‐

by‐step process to help them determine eligibility. These videos will live 

on the website as well as shared via social media. There will also be 

Spanish language transcripts of the video. We will provide these videos to 

our community partners as well. 

 Community Partner collaboration – In the first 30 days, Arkansas HAF will 

provide our local community partners with a comprehensive toolkit to 

assist them as they help us spread the word. By having state and local 

agencies, non‐profits and other faith‐based groups equipped with the 

information they need, we can ensure citizens are getting 

complete/accurate information about the program. Items in the toolkits 

include posters, flyers, bi‐lingual door hangers, pre‐crafted social media 

posts with digital assets, and FAQ documents. 

 Speaking engagements – An Arkansas HAF representative will go into the 

community speaking to groups about the HAF program. These in‐person 

gatherings serve to answer questions and share information. Special 

emphasis has been placed on the states’ top SDI communities. Our 

speaking opportunities will prioritize these areas in the first 30 days. 

 Press releases – We will distribute press releases to local broadcast media. 

The series of releases will communicate news about 1) when the portal 
will open; 2) opening day announcement; 3) ongoing updates on numbers 

and milestones.  

Performance Goals 

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

the public. 

 Once ADFA HAF program is live, we intend to publish HAF performance data via our HAF 

Program website. 

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

your program. 

 Total Number of Funded Households/Total Dollar Amount of Funded Benefits  

 Total Number of Socially Disadvantaged Funded Households/Total Dollar Amount of 

Funded Benefits to Socially Disadvantaged Household. 

 Average Days to process HAF Application (from complete application submitted to 

decisioned – approved, denied, withdrawn) 

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

 ADFA can disaggregate metrics by income, race, gender as data is available.   

 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. 

 ADFA is prepared to report homeowner referrals to housing counseling and/or legal services 

when the following conditions are met:  

• Homeowner indicates during the pre‐qualification survey (before an 

application is submitted) they are unable to resume mortgage 

payments – even if the loan was reinstated, and 

• The applicant is determined ineligible (after an application has been 

submitted) for assistance based on program criteria such as income 

>150% AMI, etc. 

Readiness 

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

including staffing, contractors, etc.. 

 ADFA has been under contract with both our vendors, HORNE LLP (HORNE) and ProLink 

Solutions (ProLink), since late May 2021.  

• Application System: The application system has largely been delivered 

by ProLink, and will be modified as additional guidance (e.g., reporting 

guidance) is release by US Treasury. HORNE has been trained on 

ProLink+ and has been working within the system for the pilot program 

since late June.  

• Call Center: The call center has been operational since June. Training 

has taken place on all current program details, as well as the application 
system. Program leadership will provide ongoing training as needed 

based on any changes. The call center is staffed at approximately half 

capacity during the pilot program. HORNE is actively advertising for the 

remaining positions but will not onboard until those resources are 

needed upon US Treasury approval. We will plan to have the remaining 

resources onboarded and adequately trained prior to the established 

statewide go‐live date.  

• Program Administration: The program administration/eligibility team 

has also been operating since the start of the pilot program in late June. 

Standard Operating Procedures (SOP) have been established and 

documented. The team is continuing to refine SOPs based on learnings 

from the pilot program, and intent to continue that effort until the 

statewide launch. The current eligibility team is staffed at 

approximately half capacity during the pilot program. HORNE is actively 

advertising for the remaining positions but will not onboard until those 

resources are needed upon US Treasury approval. We will plan to have 

the remaining resources onboarded and adequately trained prior to the 

established statewide go‐live date.  

• Marketing: Marketing has developed a robust project plan for the 

launch of the statewide program. As part of that plan, initial marketing 

materials have already been developed in preparation of the statewide 

launch. Upon approval from US Treasury, all documents will be proofed 

a final time to ensure changes, if any, have been appropriately

captured.  

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

ready to launch following approval? 

 Depending on the timing of US Treasury approval, ADFA believes we will be ready for the 

statewide launch by the end of December (assuming US Treasury approval by early December). 

As mentioned above, our call center and program administration team are operating at half 

capacity based on volume. We estimate we will need approximately two weeks to onboard and 

adequately train the remaining resources. Our marketing team estimates a two week lead time 

prior to statewide launch to properly market the program and engage interest for a successful 

statewide launch. Therefore, if US Treasury approval is provided by early December, we believe 

those items could be accomplished and a statewide go‐live date set prior to the end of 

December.  

In the meantime, ADFA is also working to streamline and expand its active HAF pilot 

results. We understand that a successful pilot is the best way to ensure readiness for 

statewide launch. ADFA, through its primary contractor, has recently engaged multiple 

team members with HHF experience to champion the Common Data File (CDF) process – 

including servicer outreach engagement and use of the CDF. Through the servicer 

outreach and onboarding effort, ADFA believes we will have an adequate number of 

servicers onboarded by mid‐December 2021 to set up for a successful statewide launch 

before month‐end. 

 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. 
 The pilot program has disbursed approximately $226,813 to 26 eligible homeowners as 

of November 15, 2021. In addition, the pilot program has obligated $1,638,150 as of November 

15, 2021. ADFA has also incurred approximately $785,263 in administration fees  

ADFA, through its primary contractor, is working to expand the outreach for the pilot 

program.  We  are  working  with  several  servicers  that  have  been  onboarded  to 

determine a viable population  to market  the pilot program in an effort  to build  the 

pilot program pipeline. Our goal is to identify additional households and exhaust pilot 

program funds by the end of December 2021.  

Budget 

 No questions.