Narrative 

Vermont’s Homeowner Assistance Fund Plan

I. HOMEOWNER NEEDS AND ENGAGEMENT

Vermont’s economy continues to struggle in many sectors, contributing to an extended need for 

mortgage assistance. The number of jobs in Vermont declined by a dramatic 7.6% between March 

2020 and March 2021—more than any other New England state. This level of job loss is the highest 

on record in Vermont and is hitting Vermont’s tourism sector particularly severely. Leisure and 

hospitality made up 12% of all Vermont jobs pre-pandemic, and the sector lost 12,300 jobs, or 34%, 

in 2020.

Vermonters’ employment losses are reflected in missed mortgage payments, which have doubled 

over the course of the pandemic. Nearly 4.4% of all Vermont mortgages were seriously delinquent in 

March 2021, compared to just 2.2% at the end of 2019, according to the Mortgage Bankers 

Association. 

The Vermont Housing Finance Agency (VHFA) has a long history of recognizing the critical 

importance of data-driven decisions when it comes to housing programs. For this reason, the 

Agency’s housing research department runs the Vermont Housing Data website 

(www.housingdata.org) and conducts in depth housing needs assessments at the state, county and 

local levels. Unless otherwise noted, data and estimates presented in this plan are based on the 

Community Profiles and reports provided through this website. 

These data are also much richer thanks to the high level of public and partner engagement 

throughout the development of this program. These contributors supplied valuable data about 

arrearages and demand for similar programs, including those funded in 2020 by the CARES Act to 

help stabilize the homes of lower income Vermonters. 

A. Data on Homeowner Needs

Vermont has a high rate of homeownership, with an estimated 182,321 homeowners, or nearly 71% 

of all households, owning their homes. As of 2019, Vermont’s homeownership rate was the 7th 

highest in the nation. 

With such a high homeownership rate, Vermont’s homeowners make up most of the state’s 

moderate-income households, making homeowner assistance especially critical. 

Household income Owner 

households

% of all VT 

households

<150% AMI 112,350 62%

<100% AMI 72,692 56%
2

Although the depth and breadth of the needs in our state is sometimes masked by its relatively 

smaller population, many factors highlight the importance of this program. These include:

• The high number of manufactured home communities (aka mobile home parks), where many 

homeowners pay higher mortgage interest rates due to limited lending opportunities;

• Higher than average home utility costs due to Vermont’s cold climate and small number of 

publicly regulated home heating options (Vermonters spend $3,454 on home energy costs on 

average —3rd highest among all states in the U.S.);

• Poorer quality of residences because of the age of Vermont’s homes (9th oldest in the nation), 

which leads to high home repair and utility costs; and

• Higher costs due to the state’s rural nature, low population density and scarcity of local 

opportunities to receive goods and services. Vermont has the 8th highest per capita consumer 

expenditure rate in the nation, according to the Bureau of Economic Analysis, 2019. 

Need for emergency mortgage assistance 

Among Vermont homeowners, approximately 63% have a mortgage on their homes. In July through 

November 2020 and again in May through June 2021, VHFA administered a CARES Act funded 

emergency Mortgage Assistance Program which demonstrated the urgent needs among Vermont 

homeowners harmed by the pandemic. Grants for over 900 households with a median income of 

$37,000 were made directly to servicers and towns for overdue mortgage payments and property 

taxes, quickly consuming the $10 million funds dedicated to the program. About two-thirds of these 

homeowners had mortgages in forbearance when they applied for mortgage assistance. 

Homeowners who needed emergency mortgage assistance in 2020-2021 were geographically 

distributed similarly to the state’s population of all mortgaged homeowners. While there appears to be

a cluster in Lamoille County, this could be an anomaly due to the county’s small population. 

Distribution of homeowners served by Vermont Emergency Mortgage Assistance Program across counties, 2020-2021
3

Despite gradual improvement in rates 

since the pandemic highs of 2020, 

Vermonters’ delinquencies remain 

well above pre-pandemic levels. FHA 

loans and VA loans continue to have 

delinquency rates above 6%, 

according to the most recent data 

available from the Mortgage Bankers 

Association and the Federal Reserve 

Bank of Atlanta. 

The rate of forbearance among Vermont homeowners has been declining, but remains elevated at 

3.7% as of March 2021, according to Federal Reserve Bank of Atlanta’s dashboards on mortgage 

performance.

Geographically, delinquency and forbearance rates and are highest in Vermont’s lower income cities, 

including Bellows Falls, Springfield and Newport as well as in several extremely small towns where 

0.00

2.00

4.00

6.00

8.00

10.00

12.00

14.00

16.00

Q119 Q219 Q319 Q419 Q120 Q220 Q320 Q420 Q121

Percentage of VT mortgages

Percentage all VT mortgages past due

All loans

Conventional

loans

FHA loans
4

estimates must be interpreted with caution, such as Alburgh in the state’s northwestern-most corner 

on Lake Champlain. 

Need for emergency utility assistance

Many lower income Vermont homeowners have urgent needs for help paying their utility expenses. 

During the August through December 2020 CARES Act funded program administered by the Vermont 

Department of Public Service, 5,590 lower income Vermont homeowners needed help due to 

pandemic hardship paying utility arrearages. This included arrearages for electricity, community 

water/sewer, natural gas, and land line telecommunication. Although arrearages peaked in August 

2020, levels in March 2021 remained significantly higher than pre-pandemic levels, according to 

information provided by the Vermont Public Utilities Commission.

Mortgage loans 30+ days past due (est.) Mortgage forebearance outstanding (est.)
5

According to the U.S. Energy Information Administration’s short term outlook, home heating fuel cost 

estimates increased for northeastern Vermont by 10-40% this winter alone. This will make the 

Vermont HAF program’s assistance for overdue utility bills of even greater importance in stabilizing 

the housing of homeowners suffering from pandemic hardship. 

Need for emergency property tax assistance

Approximately 55,000 Vermont lower income owner households do not escrow their property taxes or 

homeowners association fees. Based on VHFA’s July 2021 survey of Vermont town clerks, 

approximately 2.5% of these households have overdue property taxes. With little emergency funding 

available yet for this expense, we expect the demand for this type of assistance will continue for the 

next year and then abate slightly as the recovery continues.

Socially disadvantaged homeowners

The COVID-19 pandemic exacerbated racial disparities in outcomes among Vermont homeowners, 

as it did nationwide. The Federal Reserve Bank of Boston found recently that Black, Hispanic, and 

Asian borrowers were significantly more likely than white borrowers to miss payments due to financial 

distress, and significantly less likely to refinance to take advantage of the large decline in interest 

rates. Furthermore, Black and Hispanic borrowers were significantly less likely to exit forbearance 

and resume making payments relative to their Asian and white counterparts. Persistent differences in 

the ability to catch up on missed payments could worsen the already large disparity in home 

ownership rates across racial and ethnic groups. With even wider disparities in Vermont 

homeownership rates by race than the nation as a whole, emergency assistance for Vermont BIPOC 

homeowners is critical. 

Vermont is among the least racially diverse states in the nation, with 97% of its owner households 

headed by someone who is white alone. Despite the low number of households of color who own 

homes in Vermont, they have a disproportionately high likelihood of needing mortgage and other 

types of assistance. During the Vermont Mortgage Assistance Program in 2020-2021, people of color 

comprised 7% of the households assisted, compared to only 3% of homeowners statewide. 
6

Homeowners in manufactured home communities

Due largely to the lower cost of buying or renting a manufactured home, this home type houses a 

sizeable portion of Vermont’s lower income households. Manufactured homes present an affordable 

housing option for many Vermont residents and make up 7.2% of residential housing units in 

Vermont. Vermont’s 2019 Mobile Home Park registry lists the median manufactured home lot rent at 

$347 as compared to $945 for the median priced rental apartment. 

For one-third of the Vermont households who live year-round in a manufactured home they own, 

most are lower income and most of the homes were built prior to 1979. In addition to their advanced 

age, units built in this earlier time period are typically of poorer quality because most were built prior 

to the enactment of national basic safety and quality standards for manufactured housing. 

Many of these lower income manufactured homeowners are juggling the higher payments associated 

with chattel loans, the stress of home repair needs, and sudden economic hardship from the 

pandemic. In addition to higher interest rates, chattel loans are disproportionately used by BIPOC

home buyers and lower income home buyers and are much less likely than traditional mortgages to 

be refinanced, according to the Consumer Financial Protection Bureau.

About 6,700 Vermont homeowners live in manufactured home communities. More than 85% of these 

households have low incomes (of less than 80% of the area median), according to the most recent

survey conducted.

VT Emergency Mortgage Assistance Program participants by race, 2020-2021
7

Ongoing assessment of homeowner need

To address changes in homeowner needs in the coming years, we will analyze and report on 

Vermont’s HAF program activity relative to initial projections and performance goals every 12 months. 

Specifically, we will compare the HAF assistance provided to Vermont homeowners with our initial 

demand projections to identify areas in which homeowner needs may have shifted. By confirming 

HAF usage trends with broader quantitative data sets available through mortgage servicers, the 

National Delinquency Survey, the Federal Reserve Bank of Atlanta, Vermont’s largest utility 

providers, and the Census Bureau, we will propose any changes warranted to our HAF plan. For 

example, if the demand for utility assistance through Vermont’s HAF program during the first year 

falls short of initial projections, we will explore why this is occurring and if we confirm that needs have 

declined, we may submit a HAF plan change request to offer an additional type of assistance not in 

our original plan, such as help with home repairs. 

B. Community Engagement and Public Participation

Vermont Housing Finance Agency has sought feedback to develop the HAF plan from a wide network 

of organizations. To date, VHFA has held three virtual public meetings, which were publicized on its 

blog and social media pages. In addition, VHFA directly invited over 60 key stakeholders from across 

the state, encouraging them to participate in the meetings and/or provide written comment. These 

include: every HUD-approved homeownership center; the state’s network of housing nonprofits, 

including all five Neighborworks of America partner organizations; state and federal housing 

agencies; each legal aid group; every town’s manager and clerk; banks and credit unions; utility 

companies; the local United Way organizations; homebuilding associations; agencies serving seniors 

and people with disabilities, including our state Center for Independent Living; and organizations 

representing BIPOC Vermonters, including refugee resettlement groups and local NAACP chapters.

Feedback from these stakeholders was varied, though they largely supported the recommendations 

in the initial HAF Model Plan. Recommendations included requiring minimal documentation to the 

greatest extent possible to ease the burden on applicants and ensure efficient distribution of funding;

making payments directly to third parties such as loan servicers, towns, and utilities; providing 

applicants additional assistance and non-online options for completing the application when 

necessary, as a lesson learned from the Emergency Rental Assistance Program; and providing 

housing counseling. Vermont’s aging housing stock and the need to provide funding for necessary 

repairs was also cited as a major concern. VHFA has incorporated this feedback into this Draft HAF 

Plan.

In addition to the above feedback, VHFA has been able to draw on its experience with its Mortgage 

Assistance Fund program, which it administered between July 2020 and June 2021 with federal 

CARES Act funding. VHFA developed a network to publicize the program among their clients and 

members and to assist households who had difficulty with the online application process. These 

organizations were included in its HAF outreach. VHFA anticipates relying on this same network to 

help deploy HAF funds. 

Since submitting the HAF plan in August, we received comments from community-based 

organizations about ways to make the application process user-friendly and accessible for 
8

Vermont homeowners. Many of these recent comments stem from experiences of 

organizations involved helping applicants to Vermont’s Emergency Rental Assistance 

Program. 

Specific comments can be grouped into the following categories:

1. General needs (re expected program demands) which do not require response.

• There is a high volume of homeowners already queuing up to use the program 

including those in mobile home parks

• High volume of clients who need help with rental applications are taxing the 

capacity of some community organizations who will likely also serve homeowners 

through this program.

• Travel is needed to assist residents of mobile home parks with their applications.

2. Technical program requests which are under discussion, a planned activity, 

completed, or not planned.

• There is limited access to computers among mobile home park residents, so 

applications must be available and accessible to non-computer users.

• Response: Planned activity -- paper applications are in process of being 

created

• There is a need for a single point of contact regarding the HAP program for 

organizations to use for questions.

• Response: Planned activity.

• There is a need for a streamlined application and document upload process so 

organizations can focus on counseling and other assistance.

• Response: Completed.

• The application needs to be available in languages besides English.

• Response: Planned activity.

• There is a need for an online program checklist and guide.

• Response: Planned activity.

• There is a need for training on the application process for community-based 

organizations.

• Response: Planned activity.

• Partners requested an option to test the application and provide feedback.

• Response: Completed.

• Requested meeting with VHFA 3-6 months after launch to provide feedback and 

opportunity to make process improvements. 

• Response: Planned activity

Comments were provided through meetings we had this fall with representatives from the 

state’s HUD-approved housing counseling agencies, community action program agencies, 

and organizations that work directly with underserved homeowners including people with 

disabilities, BIPOC populations and residents of mobile home parks, including:

• Downstreet Housing and Community Development 
9

• Champlain Valley Office of Economic Opportunity 

• Opportunities Credit Union

• Windham and Windsor Housing Trust

• Neighborworks of Western Vermont

• US Committee for Refugees and Immigrants (USCRI-VT)

• BROC Community Action 

• Vermont Legal Aid

• Champlain Housing Trust 

VHFA has responded to comments from these representatives by revising application 

questions and organization, removing unnecessary questions and adding an 11th language to 

the options available through the web-based application portal. We have also designed a 

support system for agencies who will be helping customers with applications that reflects the 

suggestions these agencies provided this fall, including reimbursement for travel and 

translation expenses, staff time and having a dedicated VHFA staff person (in addition to the 

general helpline to be provided by our HAF program vendor) available for questions from 

these organizations. We have also developed a document checklist and program summary to 

make available online when the program launches. 

II. PROGRAM DESIGN

A. Program Description

1. Program Overview -- The Vermont Homeowner Assistance Fund (HAF) program offers grant 

assistance for (i) partial or full reinstatement of a delinquent first mortgage (including a forborne 

amount), principal reduction of a delinquent first mortgage in connection with a modification, or other 

mortgage related expenses (including tax and insurance escrows and late fees), (ii) delinquent 

property taxes, (iii) past due homeowner association fees or liens, condominium association fees, and 

other common charges that are or could become a lien on the property, and (iv) past due utility 

charges, including electric, gas, home energy, water, and sewer.

2. Program Goal -- To help Vermont homeowners avoid foreclosure or displacement by mitigating 

financial hardships related to the Covid-19 pandemic. 

3. Target Population -- Vermont homeowners having incomes equal to or less than 150% of the 

area median income, as published by VHFA based on household size. Priority will be given to 

homeowners with incomes less than or equal to 100% of the area median income, as published by 

VHFA based on household size, and to homeowners in Historically Underserved Populations. 

Marketing and outreach efforts also will be created to specifically engage Historically Underserved 

Populations to ensure they have an opportunity to take part in the program. In addition, at least 60% 

of HAF grants must be given to households with incomes less than or equal to the area median 

income. 

4. General Eligibility Criteria -- To be eligible, Vermont homeowners must: 

• Have experienced a financial hardship after January 21, 2020 associated with the Covid-19 

pandemic; 
10

• Have income equal to or less than 150% area median income, as published by VHFA based on 

household size (assistance will be prioritized for those with income equal to or less than 100% of 

area median income, as published by VHFA based on household size and for Historically 

Underserved Populations, and income limits may be reduced to meet the requirement that 60% of 

all HAF grants be made to household with incomes less than or equal to the area median income, 

as published by VHFA based on household size); 

• Own and occupy as a primary residence the property for which assistance is sought; and 

• Submit a hardship affidavit as explanation of a material reduction of household income or material 

increase in household expenses. 

5. Property Eligibility Criteria -- One- to four-family Vermont properties and condominiums in 

Vermont, including manufactured homes. Property must be the applicant’s primary residence. 

6. Structure of Assistance -- The Vermont HAF program provides one-time lump sum assistance 

grants for the benefit of eligible Vermont homeowners. Loans in forbearance are eligible. Funds are 

paid directly to the existing mortgage servicer, tax authority, lien holder, or applicable utility 

company(ies).

Assistance can be used to pay, but may not be limited to: 

• Delinquent principal, interest and mortgage escrow payments (including tax and insurance 

escrows), including past due fees and charges, including attorney's fees related to 

foreclosure/forbearance or similar services

• Delinquent tax and insurance payment advances by Reverse Mortgage holders

• Delinquent property taxes 

• Delinquent Homeowner Association fees and other common charges that are or could become 

liens related to the property

• Past due utility charges, including electric, gas, home energy, water, and sewer

• Delinquencies can include periods prior to January 21, 2020. 

7. Per Household Assistance – Up to $30,000 of HAF assistance is available per household across 

all HAF program grants. This cap is subject to adjustment based on program usage and applicant 

needs. This limit is based on expected demand for assistance and expected grant amounts based on 

available data pertaining to combined mortgage, utility, property tax and association fee assistance

needs per homeowner. This includes an allowance for future increases in heating fuel costs based on 

the U.S. Energy Information Administration’s short term outlook estimates increased costs for 

northeastern Vermont by 10-40% this winter alone. 

Assistance to any particular household will be prioritized in the following order: mortgage assistance, 

property tax assistance, assistance with homeowner association fees and other common charges, 

utility assistance. 

8. Program Inception/Duration – Commencing within 45 days after HAF Plan approval by US 

Treasury and running until September 30, 2025 or until program funds are exhausted. 

9. Historically Underserved Populations include Socially Disadvantaged Individuals as defined in 

HAF Guidance provided by the US Treasury and owners of mobile homes in mobile home parks. 
11

10. Counseling and Legal Services Grants – In addition to assistance to homeowners outlined above, 

up to 5% of the program funds received may be granted to HUD-approved non-profit housing 

counseling agencies and non-profit legal services providers for efforts targeting households meeting 

the Eligibility Criteria set forth above related to prevention of foreclosure or displacement. 

Organizations will be required to apply for funding, and their applications must include: 

• a strategic outreach plan; 

• a detailed description of how they will assist targeted homeowners under the VT HAF program with 

application submission; and 

• a description of how they will assist borrowers in negotiations with lien holders, mortgage 

servicers, tax collecting authorities, insurance providers, and investor groups.

B. Application Process

Homeowners must attest that they experienced financial hardship after January 21, 2020. The 

attestation must describe the nature of the financial hardship (for example, job loss, reduction in 

income, or increased costs due to healthcare or the need to care for a family member). 

For the purposes of determining income eligibility, the VT HAF program 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. 

Income Verification Requirements.

To confirm income for eligibility and targeting, the homeowner must provide the following: 

• A written attestation as to household income, and documentation of income such as paystubs, 

W-2s or other wage statements, IRS Form 1099s, tax filings, depository institution statements 

demonstrating regular income, or an attestation from an employer

• The Agency may also provide waivers or exceptions to these documentation requirements, as 

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

practical challenges related to the pandemic or a lack of technological access by homeowners 

when alternative documentation or income verification is available. In such instances VHFA 

may rely on fact-based proxies such as whether the homeowner can provide proof of current 

receipt of benefits under a federal means-tested program which requires income to be at or 

below that required income for an eligible homeowner under HAF (such as Supplemental 

Nutritional Assistance Program/SNAP (3SquaresVT) or Medicaid) or the location of the 

residence in a census tract with one of the following designations:

a. FHFA Duty to Serve designations of Areas of Concentrated Poverty 

b. HUD designations of Racial and/or Ethnic Areas of Concentrated Poverty 

c. FFIEC designations of distressed, underserved, poverty, remote rural and/or 

unemployment 

d. HUD designations of Qualified Census Tracts for use in the Low-Income Housing Tax 

Credit program

e. Other fact-based proxy eligibilities may be developed as data becomes available.
12

For homeowners requesting assistance reinstating a mortgage or other property-secured loan 

(including a forward mortgage or reverse mortgage, a chattel loan on manufactured homes, a land 

contract or other installment loan), the homeowner will be required to provide information regarding 

the loan and the loan servicer, including a copy of their most recent statement. Servicers will be 

required to confirm the delinquent balance and provide information confirming that the original loan 

balance did not exceed then-applicable conforming loan limits

Homeowners requesting assistance with respect to property taxes, homeowner association fees, 

utilities, and other homeowner costs will be required to provide information regarding past due 

amounts and a copy of the most recent related statement. The relevant taxing authority, homeowner 

association, utility, etc. will be required to confirm the delinquent balance.

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), the application asks homeowners to indicate if they are at risk of losing their home or of utility 

shut off within the next 30 days. If they answer “Yes”, their application will be prioritized with the 

intent of keeping them in their home with as minimal utility service interruption as possible. 

C. Methods for Targeting HAF Funding

In connection with its management of its Mortgage Assistance Program, VHFA developed a network 

of non-profit partners to publicize the program among their clients and members and to assist 

households who had difficulty with the online application process. These organizations were included 

in all HAF Plan outreach so far. VHFA anticipates relying on this same network to help deploy HAF 

funds. Applicants with household incomes less than 100% of area median or who are members of 

Historically Underserved Populations will be given priority in the application review and approval

process.

Although we plan to launch the program with eligibility up to 150% AMI, we will continually 

monitor the portion of approved grant amounts paid on behalf of applicants above 100% AMI. If 

this reaches 30%, we will reduce affordability to 100% AMI for applicants who are not socially 

disadvantaged as a way of ensuring we will remain within program limits. In addition, 

applications from Socially Disadvantaged Individuals will be prioritized to ensure that grants to 

these homeowners are paid as quickly as possible. 

98% of Vermont residents speak only English or speak English very well in addition to another 

language. However, there is a growing population of people with limited English proficiency in 

Vermont due to a robust Refugee Resettlement program. The HAF program will target outreach 

and provide access to homeowners with limited English proficiency through a multi-pronged 

approach: (1) bringing in as HAF program affiliates the two community-based organizations that 

most closely serve new Americans in VT: Vermont Association of Africans Living in Vermont 

(AALV) and the U.S. Committee on Refugee and Immigrants (USCRI-VT) who will ask 

ambassadors to share information about the HAF program with LEP communities; (2) building a 

relationship with the Ethiopian Community Development Council branch that just opened in VT; 

(3) translating program marketing materials into the top 10 non-English languages spoken in 

Vermont including digital search and display advertising, short videos, and program flyers; (4) 

translating application portal content, paper applications in 10 languages and providing Call 
13

Center operators in all languages; and (5) monitoring applications to add promotional activities for 

towns and population segments that are under-represented. 

VHFA has started and will continue to obtain regular feedback on HAF marketing approaches 

through its network of 17 community-based organizations serving socially disadvantaged 

individuals, homeowners with limited English proficiency and homeowners with low incomes. In 

addition to helping homeowners with applications, these organizations will use their networks and 

proven outreach strategies to disseminate HAF program information in culturally relevant ways. In 

addition, VHFA has developed connections to several hundred other statewide and local 

organizations that will use platforms and networks tailored to their mission and customers to share 

HAF program information.

D. Informing about housing counseling, legal services and loss mitigation 

options

The VT HAF application will encourage applicants who are uncertain about the affordability of their 

monthly payments in the long run to seek housing counseling and will connect applicants 

requesting counseling with HUD-approved counseling agencies. Vermont’s housing counselors are 

well equipped to help each homeowner they work with to make the adjustments needed to ensure 

that their housing is stable and their monthly housing expenses affordable and sustainable in the 

long run. 

For both legal and housing counseling, the HAF application will describe the potential benefits of 

these services and provide several opportunities throughout the application to request them. This will 

include a section that asks the applicant whether they expect to be able to afford their housing 

payments in the long run, given their expected future income. To the extent that they have concerns

about this, the application will encourage them request housing counseling. 

Vermont’s HAF program will connect dedicated staff at the Vermont Legal Aid Office of every 

applicant who indicates a need on their application for legal services. Similarly, the program will notify 

a HUD-approved housing counseling agency when an applicant requests counseling services. As 

needed, housing counselors and Vermont Legal Aid attorneys will support HAF applicant 

engagement with mortgage servicers regarding loss mitigation. 

Vermont’s providers of housing counseling have limited capacity. For this reason, we are also in the 

process of arranging for the option of phone counseling via a national HUD-approved housing 

counseling provider. 

The VT HAF application will advise applicants requesting mortgage assistance of the availability of 

loss mitigation options and ask them to describe their communication with mortgage servicers 

including the status of options the servicer has offered. This information will be used by providers 

of housing counseling and legal services who will facilitate applicant engagement with mortgage 

servicers regarding loss mitigation as appropriate. 
14

E. Best Practices and Coordination with Other HAF participants

VHFA will draw on its experience managing its Mortgage Assistance Program in developing 

processes and procedures for HAF. In addition, through its affiliation with the National Council of 

State Housing Authorities (“NSCHA”), VHFA has been communicating with peer housing agencies on 

a regular basis since it was selected to administer the HAF program. The weekly meetings between 

staff of state housing finance agencies have provided a platform for sharing best practices and 

innovative ideas. VHFA has relied on the availability of a common template library, through which 

states can share draft templates of programs, applications, requests for proposals (“RFPs”) and other 

documents. These resources have aided VHFA in developing its draft program. VHFA has also been 

engaged in the NCSHA joint meetings with mortgage servicers in developing a common data platform 

for exchanging information regarding delinquent mortgages.

F. Performance goals

To communicate our progress to the public in meeting performance goals, we will display a live 

web-based dashboard of program activity and impact metrics on the program website. For a 

similar mortgage assistance program funded with CARES Act funding in 2020 and 2021, this 

dashboard was available online and updated weekly. You can see that site here: 

https://www.vhfa.org/partners/initiatives/program-impacts/map

In addition, we will prepare annual reports on the impact of Vermont’s HAF program relative to 

performance goals and community wide trends. The Vermont Agency of Commerce and 

Community Development will also out on Vermont’s progress toward HAF performance goals. This 

will include reporting the number of HAF applicants assisted solely through counseling or legal

services without payment of HAF funds to resolve the homeowner’s defaults or delinquencies.

These three metrics will be the most indicative of the program’s success: 

1. Households assisted by income level (<50% AMI, 50-80% AMI, 80-100% AMI, 100-

150% AMI) in comparison to homeowner households statewide by income level. 

2. Distribution of households assisted by county relative to distribution of total population 

of homeowners.

3. Portion of households assisted who are BIPOC as compared to portion of all VT 

homeowners who are BIPOC. 

G. Readiness

VHFA has chosen a vendor for development of an application portal and application 

management, and we have been working with them to develop systems and processes. VHFA 

has assigned various existing staff members to its Homeowner Assistance Program team and has 

hired one dedicated staff member for the program. Additional staff may be hired as needed. We 

are actively negotiating agreements with outreach partners, legal services, and HUD-approved 

housing counseling agencies. We have met with the state’s largest utility provider to plan out the 

utility arrearage payment process, and have closely followed the national discussions with major 
15

servicers and plan to adopt the standardized process agreed upon by state housing agencies and 

loan servicers.

So far, the initial 10% payment of Vermont’s total HAF allocation has been used for payments to 

our vendor for development of the application portal and for development of systems and 

processes to manage the program and for staff planning and program development. As of this 

time, $1,057,315 has been spent for these purposes. Because VHFA had just completed a round 

of CARES Act funded mortgage assistance which closed in June 2021, no pilot program was 

offered using Homeowner Assistance Fund money to allow for the Agency to focus on developing 

the Homeowner Assistance Program. Additionally, the state used CARES Act funds to provide 

well over $15 million in utility arrearage funding to households and businesses through a program 

that was open through October 2021. 

III. Budget estimates 

The demand for assistance from Vermont homeowners is expected to exceed Vermont’s $50,000,000 

HAF allocation. The following estimates were developed by VHFA’s research department based on 

input from utility providers, town clerks, community and state home repair programs and housing 

counseling and legal service providers. Additional sources for these estimates include experiences 

during the 2020 Vermont Mortgage Assistance Program and Vermont Utility Arrearage Assistance 

Program and actual and projected mortgage delinquency rates. 

Projected expenditures ($) 2021 2022 2023

Mortgage reinstatement + 9,603,045 9,224,647

Utilities 4,512,667 6,068,790

Internet service 1,246,645 857,586

Insurance 1,206,608 1,159,216

Association fees 2,315,152 2,223,926

Property taxes 3,656,332 3,512,258

Home repairs or accessibility 

improvements 1,680,924 1,680,924

Counseling/legal 683,000 698,000

Program grants (total) 24,904,374 25,425,346

Administrative expenses 5,000,000 2,267,304 232,696

Annual total $5,000,000 $27,171,678 $25,658,042 

Cumulative total $5,000,000 $32,171,678 $57,829,720 

Due to the limited funds available through the HAF, VHFA proposes prioritizing funding for expenses 

which put vulnerable Vermont homeowners most at risk of foreclosure and/or housing displacement

and for counseling and legal services to ensure that program access and support extends fully to 

socially disadvantaged individuals and residents of manufactured home parks. Due to the direct lien 

consequences that occur when delinquencies occur with regard to mortgages, utilities, association 

fees and property taxes, VHFA plans to dedicate funds for these programs first. Utility assistance 

through HAF will begin after the current CARES-Act funded Vermont Department of Public Service 
16

program ends. As shown below, focusing on the top priority programs is expected to consume 

Vermont’s total HAF allotment of $50 million in 2023. 

Projected expenditures ($) 2021 2022 2023

Mortgage reinstatement + 9,603,045 9,224,647

Utilities 4,512,667 6,068,790

Association fees 2,315,152 2,223,926

Property taxes 3,656,332 3,512,258

Counseling/legal 683,000 698,000

Program grants (total) 20,770,196 21,727,621

Administrative expenses 5,000,000 2,267,304 232,696

Annual total $5,000,000 $23,037,500 $21,960,317 

Cumulative total $5,000,000 $28,037,500 $49,997,817