HOMEOWNER ASSISTANCE FUND PLAN

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OREGON

HOMEOWNER ASSISTANCE FUND PLAN

U.S. DEPARTMENT OF THE TREASURY SUBMISSION
HOMEOWNER ASSISTANCE FUND PLAN

September 28, 2021 2

Table of Contents

I. Overview 3

II. OREGON Homeowner Needs ANALYSIS 5

Needs Analysis Overview 5

Mortgage Landscape in Oregon 5

Delinquencies 5

Forbearance 6

Foreclosures 7

Demographics of Oregon Homeowners 8

Geographic Distribution of Homeowners 9

Economic Hardships in Oregon 12

Cost Burden 14

III. STAKEHOLDER AND PUBLIC Engagement 17

Stakeholder and Public Engagement 17

Collaboration with Other Stakeholders and Partners 18

IV. Prioritization 18

Homeowners Most At-Risk of Foreclosure18

Low-Income Homeowners 19

Socially Disadvantaged Individuals 19

Rural Homeowners 20

Homeowners Displaced by Natural Disasters 20

V. OUTREACH 20

Targeted Outreach to Homeowners 20

Informational Programming for Homeowners 21

Housing Clinics for Culturally Specific Organizations 21

Legal Aid Engagement 22

VI. Program Design 22

Mortgage Reinstatement Program24

Forward Payment Assistance 25

Application Process26

Payment Process 26

Quality Assurance 27

VII. Performance Goals 27

Mortgage Goals 27

Socially Disadvantaged Individuals 28
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Additional Areas of Interest 29

VIII. Readiness 29

Hardest Hit Funds Experience 29

Pilot Program 29

Staffing and Systems 30

Timeline 30

Contracts and Partnerships31

IX. Budget 31

Qualified Expenses 31

Counseling, Education, or Legal Services 32

Reimbursement of Funds Expended After January 21, 2020 32

Allocation of Administrative Expenses 32

III. CONCLUSION 33

I.OVERVIEW

The economic implications of the COVID-19 pandemic have reached far and wide, causing a 

significant negative impact to Oregon homeowners throughout the state. According to March 

2021 Corelogic data, about 2.49% of Oregon homeowners were 90+ days delinquent (14,225 

loans) and about 0.11% were in foreclosure (628 loans). The foreclosure figures may be 

artificially low because the Oregon legislature enacted a foreclosure moratorium to protect 

Oregon homeowners during the pandemic. This moratorium is currently set to expire on 

December 31, 2021. At the same time, the Cares Act allowed many impacted homeowners to 

enter a pandemic forbearance, pausing their monthly mortgage loan payments for one year or 

more. Many of the federal pandemic foreclosure and forbearance protections will also end in 

2021. At that time homeowners will be required to reinstate their mortgages or pursue other loss 

mitigation options to avoid foreclosure and displacement. Information and assistance within our 

communities is drastically needed to help homeowners navigate these complex processes while 

in or emerging from this crisis. 

The Homeowner Assistance Fund (HAF) is one option to assist homeowners facing financial 

hardship. On March 11, 2021, President Biden signed into law the American Rescue Plan Act 

(ARPA), setting aside a total of $1.9 trillion in federal funding in response to the coronavirus 

pandemic and its impacts on Americans, local jurisdictions, businesses, and the US economy. 

Section 3206 of the ARPA established the HAF and allocated approximately $9.9 billion in federal 

funding to states, territories, and tribal governments to assist low- and moderate-income 

homeowners who have experienced a financial hardship associated with the coronavirus 

pandemic. The State of Oregon will receive $90,937,920 from the HAF. Oregon Housing and 

Community Services (OHCS) has been designated as the entity to administer those funds.

HAF was established to prevent homeowner displacement, foreclosure, mortgage delinquencies, 

defaults, and loss of utilities or home energy services. The United States Department of the 

Treasury (Treasury) published HAF Guidance on April 14, 2021, which was updated on August 2, 
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2021 and may be found at: https://home.treasury.gov/system/files/136/HAF-Guidance.pdf. This 

guidance requires Oregon to complete a data-driven needs analysis, informed by stakeholder and 

public feedback, to develop responsive assistance programs and performance goals that will be 

submitted for Treasury review and approval as a “HAF Plan.” This document and the program 

terms attached as appendices are OHCS’ HAF Plan. This plan proposes two initial relief 

programs aimed at avoiding foreclosure and displacement of low- and moderate-income 

Oregonians. OHCS believes the attached Mortgage Reinstatement Program and the Forward 

Payment Assistance Program will best address the needs of Oregon homeowners and achieve 

the goals set forth in ARPA and the Treasury Guidance.

Treasury’s mandate to use the HAF programs to prevent homeowner delinquencies, foreclosures, 

loss of services, and displacement falls squarely within OHCS’ mission to provide stable and 

affordable housing so that Oregonians may live free from poverty and pursue prosperity. The 

ARPA and Treasury requirements for engagement, public participation, and consideration of 

equity are in line with OHCS’ core values and desire to “put the people we serve front and center 

to ensure equitable outcomes.” The initiative also presents a mission opportunity to engage and 

collaborate with state and local leaders to develop a permanent program to support Oregon 

homeowners and homeownership through future individual or economy-wide crises and 

hardships.

The HAF programs will further the goals of Oregon’s Statewide Housing Plan (SWHP). The 

programs will further the SWHP Equity and Racial Justice Priority by meaningfully engaging 

culturally specific and responsive organizations and their constituents, designing support 

programs free from barriers, filling OHCS data gaps, preventing further displacement, increasing 

access to housing resources, and directly preserving and fostering asset building for communities 

of color. Throughout this plan these communities are referred to as “Socially Disadvantaged 

Individuals” (SDI). Under ARPA and the Treasury guidance, this term is defined for HAF to mean:

Socially disadvantaged individuals are those whose ability to purchase or own a home has 

been impaired due to diminished access to credit on reasonable terms as compared to 

others in comparable economic circumstances, based on disparities in homeownership 

rates in the HAF participant’s jurisdiction as documented by the U.S. Census. The 

impairment must stem from circumstances beyond their control. Indicators of impairment 

under this definition may include being a (1) member of a group that has been subjected to 

racial or ethnic prejudice or cultural bias within American society, (2) resident of a majorityminority Census tract; (3) individual with limited English proficiency; (4) resident of a U.S. 

territory, Indian reservation, or Hawaiian Home Land, or (5) individual who lives in a 

persistent-poverty county, meaning any county that has had 20% or more of its population 

living in poverty over the past 30 years as measured by the three most recent decennial 

censuses. In addition, an individual may be determined to be a socially disadvantaged 

individual in accordance with a process developed by a HAF participant for determining 

whether a homeowner is a socially disadvantaged individual in accordance with applicable 

law, which may reasonably rely on self-attestations.

While other terms exist for communities that have been systematically excluded or traditionally 

underrepresented, this plan will use SDI for consistency with Treasury guidance. In furtherance of

Treasury guidance and the SWHP Equity and Racial Justice Priority, additional information on 

SDI homeowners is specifically included throughout this plan.
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II. OREGON HOMEOWNER NEEDS ANALYSIS

Needs Analysis Overview 

This needs analysis provides a statewide overview of current data relating to homeowner 

demographics, the mortgage landscape in Oregon, and housing cost burden for homeowners. The 

data presented in this analysis only tells a small part of the story of Oregon homeowners and their 

needs as it relates to hardship due to the pandemic. While this data will be analyzed at the state level, 

the HAF program must be designed to reflect regional variation and aim to meet the unique needs of 

different geographies. 

This analysis uses data from the American Community Survey (ACS) 2015-2019, Corelogic Market 

Trends, the CHAS 2013-2017, Atlanta Fed, and other research reports done during the pandemic. 

Most of the data can generally be disaggregated by county, race, income, and cost burden. However, 

Oregon data on individual mortgages cannot to be disaggregated by race, income, or other factors of 

SDI groups. OHCS disaggregates data based on race, ethnicity, gender, geography, education, and 

other factors, when possible, to demonstrate the needs of those groups that have been traditionally 

excluded from homeownership opportunities and wealth generation, particularly communities of color, 

LGTBQIA persons, and women. While this level of detail is not always available, it demonstrates that 

there is always a large gap in the data used to make decisions and that additional, more inclusive 

methods of data collection, specifically qualitative data collection, should be incorporated into any 

further analysis. 

Mortgage Landscape in Oregon

DELINQUENCIES

Delinquency occurs when a borrower misses a mortgage payment. Delinquencies for this report refer 

to missed payments over 90+ days. Oregon has seen a rise in the rate of mortgage delinquencies, 

which rose from 0.84% to 2.65% over the course of the pandemic from January 2020 to February 

These HAF programs will also support the Homeownership and the Rural Communities Priorities 

of the SWHP. The former by expanding and better coordinating financial tools and other 

programs to support low- and moderate-income homeowners to stay in their homes, perhaps with 

permanent support programs remaining after the Treasury’s HAF term ends. And the latter by 

helping to preserve and revitalize rural community housing stock, supporting families that may 

experience disproportionate economic hardship or housing burdens, and by building an additional 

bridge to rural local governments, partners, and lenders.

The HAF programs come at a critical time for Oregon homeowners. OHCS is balancing its 

obligations for planning under the Treasury guidance with the need to move quickly, to 

supplement other federal, state, and mortgage servicer relief that may be available to help 

homeowners reinstate their mortgages and avoid foreclosure. This plan contains the Oregon 

homeowner needs analysis, reviews our engagement, discusses our prioritization and outreach 

plans, describes how Oregon’s programs deviate from Treasury guidance, and addresses some 

administrative topics before laying out our initial program terms in the appendices.
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2021. This increase of 11,460 delinquencies represents a growth rate of 333% (Figure 1). The rate of 

delinquencies varies from county to county, but all counties saw an increase during the pandemic. 

The following counties experienced delinquencies at a higher rate than the state average: 

Multnomah, Lincoln, Yamhill, Umatilla, Sherman, Malheur, Lake, Klamath, Josephine, Columbia, 

Douglas, and Jackson. These counties cover urban, rural, coastal, Eastern, Southern, and Central 

Oregon, which shows that homeowners across the state are struggling to pay their mortgage. The 

delinquency data indicates the need for a statewide mortgage reinstatement program.

Figure 1. Average Rate of 90+ Day Delinquencies in Oregon from January 2020 – February 2021. 

Data shows the proportion of mortgages that have been delinquent for more than 90 days at the 

specific point in time at the state level. Mortgages that are delinquent carry over month to month. 

Data comes from Corelogic Market Trends dataset.

FORBEARANCE 

Many homeowners have entered forbearance plans or other loss mitigation strategies during the 

pandemic. Forbearance allows homeowners who are struggling to make partial mortgage payments 

or defer payments while interest continues to accrue. Nationally, 2.4 million mortgages are in 

forbearance without payment, so we can infer that this may be the case for mortgages still in 

forbearance in Oregon (JCHS, 2021). The average rate of forbearance peaked in June 2020 and has 

been declining since then (Figure 2). This is likely due to many mortgages exiting forbearance with 

payment plans, mortgages being brought current (reinstatement), or mortgages getting paid off 

(JCHS, 2021). Some homeowners in forbearance may be unable to reinstate their mortgages or 
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resume their monthly payments after exiting forbearance. The HAF mortgage reinstatement and 

forward payment assistance plans could help these at-risk homeowners.

Figure 2. Average Forbearance Rates in Oregon. Data shows the proportion of mortgages that are in 

forbearance during the pandemic at the state level. Data spans from April 2020 – Jan 2021. Data 

comes from the Data comes from the Atlanta Fed calculations using Black Knight’s McDash Flash 

daily mortgage performance data (available with a two-day lag), U.S. Census Bureau 2017 FIPS 

Codes.

FORECLOSURES

When borrowers cannot reinstate their mortgages and are delinquent, their loans are referred to 

foreclosure. In this step, the bank forces the sale of the home, either judicially or non-judicially 

through a trustee’s sale, to recoup the mortgage debt. The foreclosure rate in Oregon has declined 

during the pandemic from January 2020 to February 2021 (Figure 3). This is likely due to federal 

protections, such as pandemic forbearance, foreclosure prevention, and new loss mitigation options, 

and Oregon’s statewide foreclosure moratorium, which will expire December 31, 2021. While the 

moratoria have slowed the rate of foreclosures, there are more than 600 homeowners currently in the 

process of foreclosure (Figure 3) and once the moratoria end, Oregon will likely experience an 

increase in the number and rate of foreclosures. Given the current timelines and strong federal 

reinstatement and loss mitigation rules and options, Oregon believes that most homeowners will have 

far better protections and options than those available during the Great Recession. For homeowners 

that may not qualify for these other protections and options, OHCS hopes that its HAF programs will 

help those homeowners avoid foreclosure. As described later, OHCS plans to prioritize homeowners 

most at risk of foreclosure in its HAF programs.
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Figure 3. Average Foreclosure Rates during the Pandemic. Data shows the proportion of mortgages 

that have entered foreclosure over the pandemic at the state level. Data spans from January 2020-

February 2021. Data comes from the Corelogic Market Trends dataset.

Demographics of Oregon Homeowners

A recent OHCS Regional Housing Needs Analysis revealed a significant shortage of affordable and 

available housing as well as stark inequities in access to housing. There is not a large enough supply 

of low-income housing to meet the needs of Oregon residents, which highlights the need for 

programs focused on housing stability during the pandemic. 

In Oregon, the homeownership gap in race and ethnicity is extreme. As the table below shows, 85% 

of homeowners in Oregon identify as White non-Hispanic, with the remaining percentages in the low 

single digits or even less than one percent. Non-Asian people of color are less likely to own homes in 

Oregon: only 29% of Pacific Islanders, 39% of Black or African Americans, 53% of other races, and 

59% American Indians or Alaska Natives, compared to the rate of 67% for white Oregonians (OHCS, 

2021). To reconcile this data, while 67% of white Oregonians own homes (a number equivalent to 

85% of all Oregon homeowners), only 39% of Oregon’s Black or African American population owns a 

home (equivalent to 0.89% of all Oregon homeowners). In Oregon, this difference can be traced to 

the systematic exclusion of Black or African American populations from homeownership.
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Table 1. Demographics of Oregon Homeowners. Data represents the proportion of homeowners who 

identify as a specific race. Data is at the state level. “Alone” indicates respondent selected “nonHispanic” as their ethnicity. The data come from the American Community Survey 5-year estimates 

2015-2019 table B25003A-I.

Due to both the lack of affordable housing for low-income Oregonians and these large disparities in 

homeownership, it is crucial that the HAF program prioritize low-income Oregonians and communities 

of color. Further emphasizing this need, communities of color are more likely to have experienced 

hardship due to the pandemic (JHCS, 2021). 

Geographic Distribution of Homeowners

This section describes the distribution of homeowners of different racial backgrounds across the 

state. The state is divided into 12 regions: Metro, North Coast, Mid-Willamette Valley, South 

Willamette Valley, South Coast, Southern Oregon, North Central Oregon, Central Oregon, South 

Central Oregon, East Central, Northeast, and Eastern Oregon. The following highlights the proportion 

of homeowners of a given racial group that live within the region, as well as the proportion of 

homeowners in that region.

Table 2. Homeowner Demographics by Region. Data represents the proportion of homeowners within 

a racial group that reside in a specific region. For example, 0.98% of all Asian homeowners live in the 

Central Oregon region. “Alone” indicates respondent selected “non-Hispanic” as their ethnicity. The 

data come from the American Community Survey 5-year estimates 2015-2019 table B25003A-I.
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Figure 4. Map of the Distribution of Homeowners across Oregon Regions. This map represents the 

proportion of total homeowners that live in a specific region ex: 2% of all homeowners live in the 

South-Central region. The data come from the American Community Survey 5-year estimates 2015-

2019 table B25003A-I.

The Portland Metro region (Multnomah, Clackamas, and Washington counties) represents 42% of the 

homeowner population (Figure 4). It has the highest density of non-White homeowners: 

approximately, 30% of all American Indian or Alaska Native homeowners, 82% of all Asian 

homeowners, 80% of all Black or African American homeowners, 40% of all Latino/a/x homeowners, 

55% of all Pacific Islander homeowners, 42% of all homeowners who identified as a race other than 

those listed, and 43% of all homeowners belonging to more than one racial group live in this region 

(Table 2). 

The North Coast region (Clatsop, Columbia, and Tillamook counties) is a rural region that represents 

3% of the homeowner population (Figure 4). It has a some of the smallest populations of non-White 

homeowners: 1.66% of all American Indian or Alaska Native homeowners, 0.71% of all Asian 

homeowners, 0.88% of all Black or African American homeowners, 1.45% of all Latino/a/x 

homeowners, 1.82% of all Pacific Islander homeowners, 0.96% of all homeowners who identified as a 

race other than those listed, and 3.37% of all homeowners belonging to more than one racial group 

live in this region (Table 2). 

The Mid-Willamette Valley region (Marion, Yamhill, and Polk counties) represents 12% of the 

homeowner population (Figure 4). This region has the second largest population of non-White 

homeowners: 10.81% of all American Indian or Alaska Native homeowners, 4.33% of all Asian 

homeowners, 5.55% of all Black or African American homeowners, 21.24% of all Latino/a/x 

homeowners, 19.27% of all Pacific Islander homeowners, 25.12% of all homeowners who identified 

as a race other than those listed, and 11.30% of all homeowners belonging to more than one racial 

group live in the area (Table 2).
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The South Willamette Valley region (Lincoln, Benton, Linn, and Lane counties) represents 15% of the 

homeowner population (Figure 4). This is another county with a large population of non-White 

homeowners: 13.82% of all American Indian or Alaska Native Homeowners, 7.04% of all Asian 

homeowners, 8.23% of all Black or African American homeowners, 8.91% of all Latino/a/x 

homeowners, 9.51% of all Pacific Islander homeowners, 12.28% of all homeowners who identified as 

a race other than those listed, and 16.53% of all homeowners belonging to more than one racial 

group live in this region (Table 2). 

The South Coast region (Douglas, Coos, and Curry counties) represents 6% of the homeowner 

population (Figure 4). The region is considered rural and has a smaller population of non-White 

homeowners with American Indian or Alaska Natives as the largest: 9.25% of all American Indian or 

Alaska Native homeowners, 1.19% of all Asian Homeowners, 1.22% of all Black or African American 

homeowners, 2.83% of all Latino/a/x homeowners, 2.41% of all Pacific Islander homeowners, 1.25% 

of all homeowners who identified as a race other than those listed, and 7.57% of all homeowners 

belonging to more than one racial group live in this region (Table 2).

The Southern Oregon region (Jackson and Josephine counties) represents 8% of the homeowner 

population (Figure 4). This region contains a smaller population of non-White homeowner with 

American Indian or Alaska Native, Latino/a/x and Pacific Islander homeowners being the largest nonWhite groups: 6.91% of all American Indian or Alaska Native homeowners, 1.68% of all Asian 

Homeowners, 1.93% of all Black or African American homeowners, 8.31% of all Latino/a/x 

homeowners, 6.18% of all Pacific Islander homeowners, 4.03% of all homeowners who identified as a 

race other than those listed, and 6.55% of all homeowners belonging to more than one racial group 

live in this region (Table 2).

The North-Central Region (Hood River, Wasco, and Sherman counties) is a rural region along the 

Columbia River. This region represents 1% of the homeowner population (Figure 4). It has small 

populations of non-White homeowners with Native American or Alaska Native being the largest nonwhite group due to the Warm Springs Indian Reservation being located in this region: 2.57% of all 

American Indian or Alaska Native homeowners, 0.35% of all Asian Homeowners, 0.33% of all Black 

or African American homeowners, 2.05% of all Latino/a/x homeowners, 0.72% of all Pacific Islander 

homeowners, 2.01% of all homeowners who identified as a race other than those listed, and 0.85% of 

all homeowners belonging to more than one racial group live in this region (Table 2).

The Central Oregon region (Jefferson, Crook, and Deschutes counties) is made up of rural counties 

with the center of population being in Bend, OR. This region represents 6% of the homeowner 

population (Figure 4). This region is also home to the Warm Springs Indian Reservation, so the region 

has a larger population of American Indian or Alaska Native homeowners. While there is a large 

population of Indigenous homeowners, the overall region has very small proportion of non-White 

homeowners: 11.32% of all American Indian or Alaska Native homeowners, 0.98% of all Asian 

Homeowners, 0.86% of all Black or African American homeowners, 4.15% of all Latino/a/x 

homeowners, 3.32% of all Pacific Islander homeowners, 4.35% of all homeowners who identified as a 

race other than those listed, and 4.81% of all homeowners belonging to more than one racial group 

live in this region (Table 2).

The South-Central Region (Klamath and Lake counties) is a rural region that represents 2% of the 

homeowner population (Figure 4). The Indigenous population is the largest non-White population, but 

overall this region does not contain many non-White homeowners: 5.57% of all American Indian or 

Alaska Native homeowners, 0.44% of all Asian Homeowners, 0.34% of all Black or African American 

homeowners, 2.16% of all Latino/a/x homeowners, 0.52% of all Pacific Islander homeowners, 1.70% 

of all homeowners who identified as a race other than those listed, and 2.09% of all homeowners 

belonging to more than one racial group live in this region (Table 2).
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The East-Central region (Morrow, Gilliam, Umatilla, and Wheeler counties) is a rural region with two 

of the smallest population counties (Gilliam and Wheeler). This region represents 2% of the 

homeowner population (Figure 4) and has very small populations of non-White homeowners: 5.57% 

of all American Indian or Alaska Native homeowners, 0.40% of all Asian Homeowners, 0.38% of all 

Black or African American homeowners, 6.12% of all Latino/a/x homeowners, 0.39% of all Pacific 

Islander homeowners, 5.18% of all homeowners who identified as a race other than those listed, and 

2.21% of all homeowners belonging to more than one racial group live in this region (Table 2).

The Northeast region (Wallowa, Baker, Union counties) is another low population rural area. It 

represents 1% of the homeowner population (Figure 4). This region has one of the least diverse 

homeowner population: 1.22% of all American Indian or Alaska Native homeowners, 0.13% of all 

Asian Homeowners, 0.43% of all Black or African American homeowners, 0.64% of all Latino/a/x 

homeowners, 0.85% of all Pacific Islander homeowners, 0.58% of all homeowners who identified as a 

race other than those listed, and 0.67% of all homeowners belonging to more than one racial group 

live in this region (Table 2).

The Eastern Oregon region (Grant, Harney, and Malheur counties) is like the Northeast region. It is 

also a low population rural area that represents 1% of the homeownership population (Figure 4). This 

region is also one of the least diverse in the state: 0.96% of all American Indian or Alaska Native 

homeowners, 0.34% of all Asian Homeowners, 0.08% of all Black or African American homeowners, 

2.31% of all Latino/a/x homeowners, 0% of all Pacific Islander homeowners, 0.86% of all 

homeowners who identified as a race other than those listed, and 1.10% of all homeowners belonging 

to more than one racial group live in this region (Table 2).

This section shows that most of the diversity of our state is in its urban centers. Oregon’s HAF 

program needs to aid homeowners in a way reflective of the state population, including rural 

populations and diverse homeowners in urban and rural areas. The HAF program will need to ensure 

Oregon homeowners, regardless of racial identity, are not left behind.

Economic Hardships in Oregon

Most Oregon homeowners, on average, have an income above 100% of HUD area median family 

income (HAMFI). However, Black or African American, American Indian or Alaska Native, 

Latino/a/x,and those identifying as Other are more likely to be low income. Only 53%, 58%, and 52% 

of Black or African American, American Indian, or Alaska Native, and Latino/a/x homeowners, 

respectively, are above 100% area median income. Black, Indigenous, and Latino/a/x Homeowners 

are more likely than any other race or ethnicity to have incomes below 80% of area median income 

(Figure 5). In some counties there are even wider disparities among racial groups. For example, in 

Multnomah County, the county with highest concentration of homeowners. Figure 6 shows that high 

earning homeowners are more likely to be White. Black homeowners are the most likely to earn less 

than 80% of area median income (44% of all Black Homeowners). All racial groups except “Other” 

races have incomes in Multnomah County lower than the statewide average while White homeowners 

have slight improvements in income (Figure 6). 
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Figure 5. Statewide breakdown of income by race and ethnicity for Oregon homeowners. Graph 

represents average proportion of racial population at specific HUD Area Median Family Income. 

“Alone” indicates respondent selected “non-Hispanic” as their ethnicity. Data comes from CHAS13-17 

dataset Table 1.

This data highlights the need of non-White homeowners in Oregon, especially in counties like 

Multnomah because they are likely to have lower incomes (Figures 5 & 6). Across the county, 

homeowners of color are more likely to be employed in the service industry, an industry known for low 

wages and one that saw major job loss during the pandemic. Nationally, Half of Latino/a/x 

homeowners, 43 % of Black homeowners, and 39% of Asian homeowners lost income in the first 

quarter of 2021. Due to the loss of income, 17% of Black homeowners, 16% of Latino/a/x 

homeowners, and 16% of Asian homeowners were behind on their mortgages (JCHS, 2021). Due to 

these factors, Oregonian homeowners of color may be more likely to be in arrears and have fewer

resources available to pay off those arrears. In order to reach borrowers with the greatest need and 

those most at risk of foreclosure, Oregon’s HAF program will need to target these low-income 

homeowners of color. 
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Figure 6. Multnomah County breakdown of income by race and ethnicity for Oregon homeowners. 

Graph represents average proportion of racial population at specific HUD Area Median Family 

Income. “Alone” indicates respondent selected “non-Hispanic” as their ethnicity. Data comes from 

CHAS13-17 dataset Table 1.

Cost Burden

Cost burden is an important variable within the HAF needs analysis. Understanding what 

communities may not have funds to deal with financial hardship will help us determine who is likely to 

need assistance. Cost burden is traditionally defined as paying more than 30% of one’s household 

income toward housing. Cost burden is divided into severely cost burdened (more than 50 % of 

income goes toward housing) and moderately cost burdened (greater than 30%, but less than 50% of 

income goes toward housing). We examined cost burden based on income and race/ethnicity. The 

below section will highlight the key groups that will likely need assistance from the HAF program.

On average, low-income homeowners are more likely to be cost burdened than middle- and upperincome homeowners. Homeowners who are extremely low income (at or below 30% HAMFI) are 

much more likely to be extremely cost burdened (73% of severely low-income homeowners) (Figure 

7). Since most Extremely Low-Income homeowners are severely cost burdened, it is likely they have 

experienced financial hardship during the pandemic and are least equipped to deal with financial 

instability. Looking at the other income categories, approximately a third of Very Low Income, Low 

Income, and Middle-Income homeowners experience at least moderate housing cost burden (Figure 

7). Homeowners experiencing any form of cost burden are likely to have less funds available to 

endure and recover from a financial crisis, such pandemic-related hardships. Even Middle-Income 

homeowners, who we traditionally view as safe from financial stress, are cost burdened at a high rate 

in Oregon, with 35% of Middle-Income homeowners experiencing some form of housing cost burden 
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(Figure 7). Oregon’s HAF program will need to prioritize all income below 100% MFI, but especially 

those who make below 30% of the MFI. 

Figure 7. Proportion of Homeowners with Cost Burden by Income. Data represents statewide 

averages. Income groups are broken down into Extremely Low Income (<30% of HAMFI), Very Low 

Income (>30%, but <= 50%), Low Income (>50%, but <=80% HAMFI), and Middle Income (>80%, but 

<=100% HAMFI). Income is represented as HUD Area Median Family Income or HAMFI. Data comes 

from the CHAS 13-17 dataset Table 8. 

When looking at cost burden and race, all racial groups appear similarly cost burdened except for 

Black and Latino/a/x homeowners. Black homeowners in Oregon are most likely to be cost burdened 

with 41% of Black homeowners in Oregon spending more than 30% of their income on housing 

(Figure 8). In addition to being cost burdened, Black Homeowners are also more likely to have 

income below 80% MFI. On average, 36% of Black homeowners make less than 80% of MFI in 

Oregon (Figure 5). Latino/a/x are the second most cost- burdened group, with 30% of Latino/a/x 

homeowners paying more than 30% of income on housing, Figure 8, and making less income on 

average (36% of Latino/a/x homeowners make below 80% MFI) (Figure 5). 

This data highlights the need for assistance of historically and currently marginalized communities. 

Special attention should be paid to supporting Oregon’s Black homeowners, since the data 

demonstrates that this group is at highest risk for the loss of their home or leaving homeownership. 

Given Oregon’s history of Black exclusion laws and discriminatory housing policies, it is crucial that 

the HAF program prioritize high-risk non-White homeowners to ensure they can return to housing 

stability and build intergenerational wealth through homeownership. Oregon’s HAF program will 

prioritize these high-risk non-White homeowners to ensure that they are able to continue to remain 

homeowners and can continue to build wealth.
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Figure 8. Proportion of Homeowners with Housing Cost Burden by Race and Ethnicity. Data 

represents statewide averages. Income is represented as HUD Area Median Family Income or 

HAMFI. Data comes from the CHAS 13-17 dataset Table 9.

Based on Oregon’s needs analysis, and the US Treasury’s priorities and guidance, Oregon Housing 

and Community Services is committed to prioritize the following groups of homeowners:

1. Households with 100% AMI or below based upon household size.

2. Socially Disadvantaged Individual households, as that is defined by the US Treasury, including 

Black or African American homeowners, homeowners with disabilities, and other homeowners 

of color.

3. Homeowners in rural areas.

4. Homeowners most at risk of foreclosure.

References

The Joint Centers for Housing Studies. (2021). The State of the Nation’s Housing. 

https://www.jchs.harvard.edu/state-nations-housing-2021.

Oregon Housing and Community Services. (2021). Implementing a Regional Housing Analysis 

Methodology: Approach, Results, and Initial Recommendations. EcoNorthwest. 

https://www.oregon.gov/ohcs/about-us/Pages/housing-needs.aspx
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September 28, 2021 17

III. STAKEHOLDER AND PUBLIC ENGAGEMENT 

Stakeholder and Public Engagement

OHCS undertook many stakeholder and public engagement opportunities in the short amount of time 

available under our timeline. This was an agency-wide effort and we were able to secure substantial

involvement and obtain useful feedback for developing our initial programs and this plan. Members of 

OHCS’ HAF program team have provided information and updates on HAF to, and received feedback 

on homeowner hardships, needs, and programming from:

• OHCS’ internal Programmatic Policy Review Committee, receiving a unanimous green light to 

proceed with these initial HAF programs and terms without any reservations (introductory 

presentation 5/10; endorsement 7/21).

• OHCS’ statewide monthly communication calls.

• OHCS’ monthly Executive Director electronic updates.

• Introduction to OHCS’ Executive Team (5/18).

• OHCS’ Housing Stability Council (introduction 6/4; update 7/2; approval vote for HAF Plan 

submission) (the council meetings are also public meetings).

• OHCS’ Homeownership Division quarterly partner call (introduction 6/3; update 9/2).

• Oregon’s Housing Alliance Homeownership and Asset Building Workgroup (May HAF 

presentation and breakout work sessions; June update; July HAF discussion of draft program 

terms; September update).

• Oregon’s Manufactured Housing Advisory Committee (6/7).

• PUBLIC MEETING: Introduction to HAF and OHCS’ needs analysis and pilot; how to submit 

feedback (6/17).

• SURVEY: a survey was submitted to OHCS’ housing partners and housing advocates to verify 

the data in our needs analysis and solicit information on homeowner hardships, needs, and 

program options.

• A special meeting presentation and discussion with the Governor’s Racial Justice Council 

(6/23).

• PUBLIC MEETING: Update on HAF development; introduction to and discussion of program 

terms and lessons learned from hardest hit funds programs (7/1). This meeting included 

interactive polls and a virtual white board to obtain feedback and data on homeowner needs, 

lessons learned, and program options.

• PUBLIC POSTING: 7/16 to 7/23.

• Various agency employees spanning administrative (research, IT, procurement, 

communications, etc.) to program planning: energy and utility programs, lessons learned from 

hardest hit funds and rental assistance programs, manufactured housing, wildfire and disaster 

response, an equity lab exercise in policy development, homeownership centers and 

counseling programs, and Oregon’s foreclosure avoidance mediation program, among others.
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Collaboration with Other Stakeholders and Partners

OHCS participates in national calls concerning HAF development and implementation, to learn best 

practices from other states and foster administrative uniformity where possible. Some of these calls 

involve government agencies and mortgage servicers. Some include presentations from housing 

counselors, legal aid, and the federal mortgage agencies. Oregon has spoken with representatives of 

at least 14 states individually concerning their HAF program development and implementation. OHCS 

is also collaborating with the sovereign Tribes in Oregon about how these HAF programs might align 

and how OHCS may provide technical assistance. Oregon is also exploring ways to communicate 

information about HAF to its court systems, to try and help prevent foreclosures and provide 

information that may be helpful for HAF applicants in active bankruptcy.

IV. PRIORITIZATION

Oregon plans to prioritize homeowners in four categories: low-income households (100% AMI and 

below), SDI households, rural households, and homeowners most at risk of foreclosure. In addition, 

OHCS plans to fast track – within the context of these other prioritizations – homeowners that have 

been doubly impacted by covid and displacement due to natural disasters. These are not additional 

eligibility criteria; they are prioritizations of applications within the program.

OHCS believes these priorities comply with purpose of the HAF program, are responsive to the above 

needs analysis, and further the SWHP and State of Oregon Equity Framework. Governor Kate Brown 

mandated that “every state agency ... apply the State of Oregon Equity Framework” in planning for an 

equitable recovery. The HAF plan meets this requirement because it specifically considers and 

prioritizes equity, addresses racial disparities, addresses systematic wealth inequalities, and provides

infrastructure for underserved communities to return to stable and affordable homeownership 

positions as we recover. Among other categories, the minority communities named in the Governor’s 

recovery framework may be based upon race, ethnicity, citizenship status, language, disabilities, 

sexual orientation, age, economic status, or rural residency.

Homeowners Most At-Risk of Foreclosure

Oregon recognizes that it will not be able to provide all eligible homeowners with HAF assistance. We 

interpret foreclosure and displacement avoidance to be the top priority of ARPA and the Treasury 

guidance. This interpretation is in line with OHCS’ mission and values, the SWHP, and Oregon’s 

recovery framework. It is in line with the Treasury’s sample terms that preference the use of HAF 

funds to supplement other mitigation options or “where, without HAF funds, the homeowner would not 

qualify for that loss mitigation option.” We believe that homeowners in or approaching foreclosure 

have most likely exhausted their other options. Therefore, OHCS will implement its reinstatement and 

forward payment assistance programs using foreclosure and displacement avoidance as the top 

priority. 

OHCS or its program administrator will solicit foreclosure status on every application, including

requesting a sale date if a homeowner is in foreclosure. This flag will give top priority to those 

homeowners within the application process. Oregon will request that mortgage servicers pause 

foreclosures while homeowners are evaluated for HAF assistance. Where a borrower’s need exceeds 
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program caps or limitations, OHCS or its administrator will work with servicers to see if HAF 

assistance could be paired with other loss mitigation options. These borrowers will also be referred to 

both housing counselors and legal aid attorneys to help avoid foreclosure.

Oregon will attempt to prioritize applications that are most at risk of foreclosure, to catch these files 

before a foreclosure commences. We hope to include outreach material to any homeowners that 

have been referred to the state’s foreclosure avoidance program and we plan to outreach to any 

servicer that has requested an exemption from that program. We believe we can monitor county 

recordings for notice of judicial (lis pendens) and nonjudicial (notice of default) foreclosures and we 

are investigating the best ways to communicate with state and federal courts in Oregon. We also 

hope that participating servicers will engage in email, mail, and phone campaigns to Oregon 

homeowners in or near the foreclosure process, including those that are denied reinstatement or loss 

mitigation.

Treasury has asked participants to identify how they will address the needs of private mortgage 

borrowers, who often have limited loss mitigation options and are therefore at a greater risk of 

foreclosure. To the extent Oregon can identify these loans, we will flag them in this category as 

borrowers that are most at risk of foreclosure. We hope servicers will help identify and outreach to 

these borrowers. Following the spirit of Treasury’s guidance, Oregon will identify other loan types 

have limited loss mitigation options or oversight protections in foreclosure to include in the at-risk 

foreclosure priority. For example, these loans may include land sale contracts, chattel loans, of HUDowned loans. Program manuals will control the end result of this effort and the at-risk foreclosure 

prioritization category.

This priority will be the emphasis of Oregon’s phased HAF opening, which will begin with Oregon’s

pilot program in November 2021 and continue as these two submitted programs go live about the

time Oregon’s foreclosure moratorium ends. Oregon will continue opening these two programs in 

broader phases related to at-risk homeowners while monitoring the volume of foreclosure filings. 

Oregon hopes to be fully open a few months after the moratorium ends but will open more slowly if 

there is a high volume of foreclosure filings in early 2022, in order to manage the highest priority 

homeowners without risking delayed processing for other applicants.

Low-Income Homeowners

According to Treasury guidance, 60% of the amounts made available to the state must assist 

homeowners with incomes equal to or less than 100% AMI. Oregon plans to fulfill this requirement by 

constraining the eligibility of its forward payment assistance program to households at or below 100% 

AMI. Oregon has initially budgeted 30% of its award for this program, which will fulfill half of the 

Treasury’s requirement if fully allocated. In addition, Oregon will prioritize homeowners at or below 

100% AMI in its reinstatement program.

Socially Disadvantaged Individuals

Based on the Treasury guidance and the above needs analysis, SDIs will be prioritized for 

applications at income levels above 100% AMI. OHCS is establishing methods of identifying likely 

SDI homeowners based upon geography or loan type, in addition to applicant disclosure. Oregon is 

conducting targeted outreach and application assistance to these SDI communities, to be provided by 

OHCS, housing counselors, and local, trusted organizations.
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Rural Homeowners

Treasury guidance calls out the unique needs of rural homeowners several times, which has been 

repeated in both OHCS’ research data and stakeholder engagement. Rural homeowners often have 

higher living expenses and lower housing stock, especially for affordable housing. They have fewer 

options to purchase and develop property. In addition, displacement can be more severe in a rural 

community, forcing a family to move to a nearby town or county. OHCS plans to reserve a portion of 

each program for homeowners in rural-designated parts of Oregon. If funds remain after the rest of 

the program funds have been allocated, the program team will reevaluate the amount or necessity of 

the reservation.

Homeowners Displaced by Natural Disasters

Over the past few years, Oregon has seen natural disasters impact its residents, including many 

homeowners living in affordable and/or manufactured housing. After the Treasury’s covid hardship 

date of January 21, 2020, Oregon experienced massive flooding in the Umatilla area and devastating 

wildfires across the state, particularly with the Labor Day 2020 fires and air quality emergency. At the 

date of drafting, wildfires are burning in several parts of Oregon. While these disasters are not covidrelated, the families that have experienced both a qualifying covid-related financial hardship and loss 

or displacement from their home due to a natural disaster have been severely impacted. A report on 

the Oregon wildfires can be accessed here. It describes the devastation occurring at a time when 

Oregon was under emergency pandemic restrictions. It also describes the state’s wildfire housing 

recovery goals, including building family and community resilience, creating intermediate and 

permanent housing solutions, and bolstering local capacity. OHCS believes helping homeowners that 

lost their homes or experienced displacement – if they also qualify based upon a covid pandemic 

financial hardship – warrants fast tracking their applications. For this category of homeowners, fast 

tracking the application would occur within the other parameters set forth above. 

V. OUTREACH

Marketing and outreach will be imperative to the success of the program’s administration as well as 

ensuring that assistance is provided to targeted populations (low-income, socially disadvantaged 

individuals, rural communities, etc.). Outreach efforts will utilize loan and demographic data available 

to identify potentially qualified applicants. As provided in the needs analysis, the data allows us to 

narrow in on each county’s populations, work with community organizations and housing counselors,

and better understand the needs of that community. OHCS has hired an Outreach Coordinator 

specifically for HAF and has dedicated one of the agency’s strategic communications staff members 

for the initiative.

Targeted Outreach to Homeowners

Oregon will maintain a HAF website, e-newsletter updates, and provide regular updates at partner, 

council, and public meetings. OHCS will work with servicers, our vendors, and regulators to conduct 
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targeted outreach where outreach is possible through other channels. Oregon’s outreach will also

consist of collaboration and partnerships with other state agencies, local jurisdictions, non-profit 

organizations, and community leaders.

To comply with Treasury’s guidance to serve low-income, SDI, and rural households, OHCS will 

reach out to homeowners in their communities. We can target homeowners in zip codes that are 

known to be particularly impacted by covid, those with the lowest incomes, highest housing cost 

burden, and many of the SDI categories. OHCS’ HAF program outreach coordinator will be the main 

liaison for the program, including completing the targeted outreach and follow up.

Informational Programming for Homeowners

OHCS will leverage the assistance of housing counselors and other organizations within the 

community and provide them with HAF support and tailored assistance that is the most appropriate 

for the communities they serve. Communities of color tend to respond and engage with local 

organizations because of established trust and physical presence within their communities. In these 

instances, targeted outreach for OHCS means supporting these local organizations to get the word 

out, not only related to HAF but also concerning the broader mortgage and foreclosure landscape. 

OHCS has already completed engagement to better gauge the needs of these communities and will 

continue to do so as the program develops. 

To best serve these local organizations, OHCS plans to develop substantive information on 

mortgages, forbearance, reinstatement, loss mitigation, foreclosures, housing counseling, legal aid, 

and other resources. Each organization or community might then use this base of information to 

inform its constituents, creating an educational video, translating the resources into a different 

language, or hosting a sit-down among a constituency population. 

OHCS’ goal is to create a set of resources that will be more broadly available to borrowers in however 

they access information. OHCS will request informational prints, radio advertisements, digital media, 

and other materials produced by these various organizations and archive any resources provided in a 

user-friendly accessible website. This website will be maintained to provide education and inform 

potential applicants about their options coming out of forbearance, including HAF assistance. Even if 

a homeowner does not apply for HAF assistance, OHCS hopes this centralized database of 

information in various formats and languages will help provide information at this critical time.

Housing Clinics for Culturally Specific Organizations

Based upon the Treasury and program priorities and the tendency of SDI populations to trust and 

utilize local organizations, one aspect of the outreach and communication plan is to ensure that 

Oregon reaches these communities and provides training and assistance with the informational 

programming and HAF applications. OHCS is committed to working with culturally specific 

organizations and conducting in-house training clinics which will focus on an array of topics, including 

but not limited to:

• Housing and emergency service assistance available through HAF and other opportunities.

• Financial counseling and legal aid opportunities.

• Mortgage success and best practices after reinstatement.
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These clinics would occur during the first year of the HAF program implementation. Organizations 

would have access to the initial clinic as well as continual training opportunities as additional 

guidance and resources are made available through the program’s duration. By hosting or

participating in the clinic, local organizations and their representatives will be better equipped to 

inform and assist Oregon homeowners with HAF applications and other options. OHCS can use the 

HAF training material we prepare for housing counselors in this situation as well.

Legal Aid Engagement 

In many circumstances, attorney assistance is necessary to resolve questions about a homeowner’s 

options and to help homeowners understand the legal consequences of their decisions or 

agreements regarding their loans. In the Great Recession, low- and moderate-income Oregonians 

caught in the foreclosure crisis struggled to make important legal decisions without access to 

information or legal advice. To compliment the informational programming for homeowners, we plan 

to engage legal aid to represent – in litigation, in the state’s foreclosure avoidance program, and in 

transactions – homeowners at risk of foreclosure or displacement, those with unique legal needs, and 

those with legal questions that counselors and program administrators cannot answer. This legal 

assistance will help homeowners make more informed decisions about their potential mortgage 

options, avoid foreclosure or displacement, and return to stability following the pandemic. 

As with training housing counselors and outreach clinics on Oregon’s HAF programs, one aspect of 

the legal aid assistance will be the creation of a free or low-cost continuing legal education course to 

instruct new and seasoned attorneys on mortgages, foreclosures, forbearance, and loss mitigation, 

including HAF. This will broaden the reach of this investment to homeowners at all income levels that 

might be served by a new group of trained attorneys for years into the future.

VI. PROGRAM DESIGN 

The following programs were designed to prevent foreclosure and displacement of homeowners who 

are at the greatest risk of housing instability by reinstating mortgages and providing forward payment 

assistance. Over time, the programs may be adjusted to best meet homeowner needs. Eligible 

properties and loans will include single family, owner occupied 1-4 unit properties, condos, 

cooperatives, land trust homes, manufactured and mobile homes, and floating homes secured by

federally related loans, portfolio loans and private mortgages, land sale contracts, and reverse 

mortgages, which each must have been under conforming loan limit at origination.

Assistance will be structured as a five-year, non-recourse, zero percent, forgivable, non-amortizing 

loan for which a junior lien will be recorded against the property. This lien will have subordination 

requirements to protect the interests of OHCS and the homeowner. An equal amount of this loan will 

be forgiven over the loan term, at least annually. If the property is sold or a cash out refinance is 

completed prior to the loan termination date, the Program will recover funds to the extent that

sufficient equity is available from the transaction. The program shall recycle these recovered funds to 

provide additional program assistance in accordance with the program terms. These loans meet the 

expectations of the loans described in the Treasury’s sample program terms.
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Below are clarifications and reasoning for potential or actual deviation from Treasury guidance and/or 

the sample terms in both the Mortgage Reinstatement Program and Forward Payment Assistance 

Program:

• Oregon is not prioritizing applications to homeowners who have Federal Housing 

Administration (FHA), Department of Veterans Affairs (VA), or U.S. Department of Agriculture 

(UDSA) mortgages or homeowners who have mortgages made with the proceeds of mortgage 

revenue bonds or other mortgage programs that target low- and moderate-income borrowers. 

Oregon understands targeting these loans would identify income-eligible borrowers. However, 

these borrowers also have the greatest number of investor forbearance, reinstatement, and 

loss mitigation options so, as a category of borrowers, they are less at risk of foreclosure and 

displacement. If these borrowers fall into one of Oregon’s other priority categories, such as 

active foreclosure, they will be prioritized. Further, Oregon is not precluding these borrowers 

from applying and receiving assistance. We feel that this decision furthers the Treasury 

guidance and sample terms’ goal of not replacing other available loss mitigation resources.

Where there is potential conflict between this priority encouragement and Treasury’s desire to 

supplement – not replace – other loss mitigation, we decided this approach furthers the 

objectives of HAF and will still prioritize those borrowers if there are no other loss mitigation 

options (placing them in the at-risk of foreclosure priority category).

• Treasury’s sample terms permit (“may” but not “shall”) payment of “reasonably required legal 

fees” and property charges. Oregon’s terms take the inverse approach, excluding attorney 

fees, collection costs, and charges not actually paid to third parties without authorization under 

the program manuals. For pandemic-impacted borrowers, Oregon’s foreclosure moratorium

prohibited not only foreclosures but the assessment of late fees and other charges, which 

implies that legal or collections costs would not be warranted. Therefore, Oregon plans to craft 

manuals that more specifically lay out when certain fees, legal fees, or collection fees were 

“reasonably required” and will be paid. Oregon may also make exceptions where this rule 

increases the risk of foreclosure to an otherwise qualified borrower. Oregon believes this 

furthers the purpose of the statement in Treasury’s sample terms while allowing Oregon to 

determine how that statement is placed into practice.

• Oregon’s intention to reserve proportionate program funds for rural homeowners does not 

deviate from Treasury guidance or sample terms, which are silent on the rural assistance

prioritization. However, the Treasury guidance encourages focus on rural communities through 

prioritizing USDA loans and in crafting targeting and performance goals. Oregon believes this 

reservation of assistance, described as a prioritization category in the program terms, furthers 

the objectives of HAF.

• Within each of the other categories of applicants and prioritizations, Oregon plans to fast track 

applicants who experienced both a qualifying coronavirus pandemic-related financial hardship

and loss or displacement from their homes because of natural disasters. We feel this furthers 

the objectives of HAF – as these homeowners are otherwise qualified – and meets an urgent 

and ongoing Oregon homeowner need that was raised repeatedly in our stakeholder and 

public outreach.

Providing assistance for a property that is not currently occupied as a borrower’s primary 

residence is allowed under the guidance and sample terms. Both Treasury guidance and the 

sample terms limit assistance to a homeowner’s primary residence. The Treasury’s payment 

assistance sample terms expressly define “primary residence” to include “a dwelling to be 

made habitable so it may serve as the homeowner’s primary residence.” This definition 

focuses on the homeowner’s intention rather than the current status of the property. Oregon’s 
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interpretation is not prohibited elsewhere: the definition if mortgage is tied to the definition of 

dwelling, which “means any building, structure, or portion thereof that is occupied as, or 

designed or intended for occupancy as, a residence by one or more individuals.” (emphasis 

added). Again, current occupancy is not a requirement if the intention is for the property to be a 

homeowner’s primary residence.

Oregon’s program terms may differ from most states in two ways to meet this important 

homeowner need and to avoid categorical exclusion of homeowners impacted by two events 

beyond their control. First, in Oregon vacant and abandoned land or homes are ineligible 

unless the vacancy is because of a physical hazard event, casualty loss, or natural disaster. 

This provision shifts relevant properties into the eligible category. But in order for the vacant 

property (or unit) to be eligible, Oregon requires that – at the time of mortgage origination and

homeowner displacement – the property was the homeowner’s primary residence. Oregon’s 

program terms categorize second home, vacation homes, and investment property that is not a 

primary residence as ineligible property. The program terms will further clarify how to make 

these determinations when the triggering events have occurred.

The second difference is Oregon’s “prioritization” by fast tracking homeowners displaced as a 

result of natural disaster within each other prioritization category or within the general pool of 

applicants. This is a narrower category of borrowers than in the first change: just those 

displaced as a result of natural disasters. OHCS believes fast tracking these borrowers is 

appropriate given the circumstances, the borrower need, and the strong advocacy and support 

we received in the stakeholder and public engagement phases of HAF program development.

For these reasons, we believe these deviations from other states – but not Treasury guidance 

or the sample terms – furthers both HAF and Oregon homeowners assistance objectives.

Each of Oregon’s HAF programs are briefly discussed here, including any deviations particular to only 

that program.

Mortgage Reinstatement Program 

OHCS will administer a mortgage reinstatement program for the broadest category of eligible 

borrowers: those at or below 150% AMI, with prioritization to SDI homeowners for households 

between 100% and 150% AMI. Assistance for the reinstatement program is capped at $50,000, with 

a per item cap as stated in the program terms. OHCS will not exceed $60,000 in assistance per 

household between the Reinstatement Program and the Forward Payment Assistance 

Program. Additional program terms for the Mortgage Reinstatement Program are included in the plan 

appendix.

Below are clarifications and reasoning for potential or actual deviation from Treasury guidance and/or 

the sample terms in the Mortgage Reinstatement Program:

• The sample terms state that HAF funds will only be used to supplement other loss mitigation 

options or where they are essential for a homeowner to qualify for the other loss mitigation

options. Oregon did not include this requirement in its terms because Oregon law and CFPB 

rule require servicers to reach out to borrowers that self-identified coronavirus hardships (and 

sometimes those that did not) about resolution options. Oregon does plan to ask the applicant 

to attest that they have sought servicer loss mitigation options but does not plan to require 

proof of application or a denial notice. Instead, Oregon has included language in its terms 

encouraging servicers and other recipients to negotiate funding gap resolutions with servicer

loss mitigation options. In addition, Oregon’s servicer collaboration agreements encourage 
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servicers to work with borrowers on funding gap resolutions and other loss mitigation options.

We believe this meets the intended Treasury goal using an alternative method.

Forward Payment Assistance

OHCS will provide Forward Payment Assistance to homeowners with income levels at or below 100% 

AMI. Economic recovery following the pandemic has been slower for low-income homeowners. 

Throughout the pandemic many of these families were able to make ends meet with the assistance of 

state unemployment benefits, coupled with the additional weekly unemployment benefits provided by 

the United States Department of Labor (DOL). These additional benefits are set to expire or max-out 

for many recipients in the months to come. This HAF program can provide these homeowners the 

additional time and resources needed to recover from their qualified financial hardship.

The Forward Payment Assistance Programs has two mutually exclusive tracks:

1. Hardship Track. Where an Eligible Homeowner has a current and ongoing financial hardship, 

they may receive up to twelve months of payment assistance, not to exceed a total of

$15,000 per household.

2. Stabilization Track. Eligible Homeowners that do not qualify for the Hardship Track may 

qualify for the Stabilization Track to increase long-term housing stability. OHCS will not exceed 

three months of payment assistance, not to exceed a total of $3,750 per household. To qualify 

for this track, households must be cost burdened by paying more than 35% of their household 

income toward housing (Eligible Costs).

As with the Treasury sample terms, Oregon’s Reinstatement Program requires that borrowers must 

be able to resume regular payments upon reinstatement unless they are receiving assistance under 

the Forward Payment Assistance Program. In structuring these two tracks, we believe we are 

furthering HAF objectives and Oregon homeowner needs by reaching homeowners most at risk of 

foreclosure or with the greatest need for assistance and stability. Unemployed borrowers are less 

likely to be reinstated under servicer options and will have additional time to recover under the 

Hardship Track. Low-income borrowers that are cost burdened will also have limited servicer loss 

mitigation options and, if they do not have continuing hardships, would otherwise be excluded from 

the Reinstatement Program. Oregon’s needs analysis and stakeholder and public engagement 

directly influenced the design of these programs, which also further the HAF objectives.

OHCS will not exceed $60,000 in assistance per household between the Reinstatement Program and 

the Forward Payment Assistance Program. Additional program terms for the Forward Payment 

Assistance Program are included in the plan appendix.

Below are clarifications and reasoning for potential or actual deviation from Treasury guidance and/or 

the sample terms in the Forward Payment Assistance Program:

• Oregon constrained eligibility for this program to homeowners with income at or below 100% 

AMI for two main reasons. First, it will help ensure Oregon meets the Treasury requirement of

providing 60% of assistance to homeowners at this income level, doing so in a more

administratively feasible way. Second, we believe low-income homeowners have a greater

need for payment assistance because they are more likely to be adversely cost burdened and 

because unemployed or underemployed homeowners will have lower incomes by virtue of 

their change in income from pre-pandemic levels.
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• For the reasons stated above, the Stabilization Track does not require borrowers to provide a 

statement that they cannot “resume mortgage payments due to unemployment, 

underemployment, or other continuing hardship.” Applicants need not have a continuing 

hardship. For some borrowers, housing cost burden will be the result of a job change or 

income loss and may constitute a pandemic-related qualifying financial hardship. For 

borrowers that were cost burdened prior to the pandemic, suffered a qualifying hardship, but 

do not have an ongoing hardship, the Stabilization Track will help increase their housing and 

financial stability, pay down other debt, or rebuild emergency savings. For this tailored track, 

OHCS believes this deviation furthers the HAF objectives and it was strongly encouraged in 

Oregon’s needs analysis and engagement.

• Oregon will not require borrowers to exhaust all other forbearance options. We received 

feedback that to do so may unnecessarily increase arrears. We also learned that some 

servicers are requesting and granting forbearances beyond the covid forbearances. If 

traditional forbearance options are limited under loan terms, this program rule would require 

borrowers to use up all possible forbearance options for the loan. It could also cause servicers 

to term limit forbearance options with unintended consequences for other borrowers. In 

addition, the Stabilization Track of the Forward Payment Assistance Program does not require 

an ongoing financial hardship so such a requirement would preclude assistance. Finally, 

practically, Oregon’s Forward Payment Assistance Program will open nearly two years after 

the hardship date when most borrowers will have exhausted their other forbearance options. 

Oregon believes this deviation is reasonable to operate the Stabilization Track (more below) 

and in light of the circumstances and tailored program terms.

Please feel free to contact us if you have any questions about the program terms, actual or potential 

deviations, or if you identify any deviations not addressed above.

Application Process

OHCS intends for applications to be submitted by borrowers directly, through housing counselors 

where borrowers need or would like assistance, and by other authorized third parties, such as 

approved community-based organizations, powers of attorney, or a trustee. Once an application is 

submitted to the program administrator, it will be processed in the order it was received with 

prioritization given as identified in the prior section and in program manuals.

OHCS recognizes the importance of making our application for assistance available to our 

communities in various formats (i.e., paper, mobile accessible, web-based). Applications for the 

program will be provided in the multiple languages which represent Oregon’s demographics. The 

application will be designed to meet the Treasury eligibility and compliance requirements while 

reducing the documentation burden of the applicant. A secure portal will be monitored and maintained 

by the program administrator. Any documentation requested of the applicant will be communicated by 

the application processing team and the applicant will be able to review the status of the application 

and funding.

Payment Process

Payment will be issued in the form of ACH transfer, with less preferred options including bank check. 

For ACH transfers, payment data will be prepared by the program administrator, provided to OHCS 
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for reconciliation and verification, and provided to the Oregon State Treasury to initiate transfers. For 

check payments, payment data will be prepared by the program administrator, provided to OHCS for 

reconciliation, verification, and payment. Payments from the HAF program will be disbursed directly to 

loan servicers, HOA, and other entities, depending on the type of expenditure. OHCS does not intend 

for direct payments to be issued to homeowners. 

Quality Assurance

The program administrator will follow up on missing document files and complete a second look at 

many denials at the eligibility prequalification and underwriting levels. OHCS will internally handle the 

appeals processes, test a percentage of applications, and complete quality assurance work. For 

quality assurance, OHCS may conduct additional review of certain approvals or denials based upon 

specific categories to be determined in the program manuals (e.g., use of documentation exceptions, 

delinquencies prior to 1/21/20, awards reaching the per item/program/household caps, etc.). Data 

gathered during the quality assurance process will be utilized to evaluate the performance success of 

the chosen program administrator. 

VII. PERFORMANCE GOALS

For the reinstatement and forward payment assistance programs, OHCS will establish the following 

joint performance goals because the overarching goal of both program is to reinstate mortgages and 

avoid foreclosures. OHCS may evaluate performance by breaking out the two programs or by 

combining the data into an overall report on the performance of these related programs. It is worth 

noting that Oregon’s HAF programs may not have a broad impact on the statewide statistics listed 

here if HAF is oversubscribed or if many borrowers are unable to reinstate their mortgages. Oregon 

HAF is one piece of the forbearance, reinstatement, and foreclosure landscape that will all continue to 

evolve based upon federal, state, and servicer or investor action. It is for these reasons and this

uncertainty that Oregon is focusing parallel efforts on informational programming, community-level 

outreach and education, and legal aid services. Even if homeowners do not access HAF assistance, 

we hope to provide information for self-help, guided assistance through housing counselors or other 

trusted groups, and legal aid so borrowers might use one of the many other reinstatement options 

available.

With this combined approach, OHCS seeks to measure and have a strong impact in the following 

areas:

Mortgage Goals

We hope that Oregon’s HAF programs and its informational programming and outreach, along with 

other federal, state, and servicer options, will have the following effect on the statewide statistics:

• Reduce the statewide average 90+ day delinquency rate of 2.6% down to the pre-pandemic 

average of 1.0%. 

• Maintain a statewide average foreclosure rate below 0.40% (avg. rate in 2019) after 

foreclosure moratoria expire. The average foreclosure rate in Oregon at the peak of the 

Great Recession was 3.0%.

• Helping 1,000 homeowners exit forbearance using the HAF programs. Having allocated 40% 

of our HAF funds to reinstatement, we can reinstate 909 homeowners if each requires an 
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average of $40,000. One thousand is a conservative estimate but we also do not know the 

demand as compared to other reinstatement options available.

OHCS hopes to maintain specific performance data on homeowners that received funding through 

either initial HAF program. We should be able to identify the number of homeowners that reinstated 

while in the foreclosure process or pipeline. We plan to send surveys to homeowners to see if they 

remain in their homes and are current in their mortgages one year later. We may also be able to 

obtain this data from the servicers or public record. This data will be disaggregated by race, ethnicity, 

gender, income, and geography if provided by the applicant.

Socially Disadvantaged Individuals

Through March 2021, the race and ethnicity reported for Oregon’s hardest hit fund homeowners is 

below. OHSI’s priority was speed in a time of high unemployment and negative homeowner equity; 

there was no charge to address SDI communities. While the borrower data was merely collected and 

reported to Treasury, it demonstrates the importance of thoughtful planning, engagement, and 

outreach, even if the process takes longer. OHCS is committed to doing better with HAF, in 

furtherance of Oregon’s SWHP Equity and Racial Justice Priority and Treasury’s HAF guidance 

related to intentional planning and equity considerations for SDI communities. Where this information 

is provided by homeowners it will be tracked and reported.

It is worth noting that about 85% of the homeowners that reported race were white. This is very nearly

the percentage of white homeowners in Oregon. Given the race and ethnicity gap in homeownership 

in Oregon, it may be difficult to achieve a higher percentage participation of SDIs. According to May 

26, 2021 estimates on the Oregon Housing Blog, 13.4% of all owner occupants statewide are 

presumptively SDIs. We hope that targeted outreach through community organizations and marketing 

can help preserve homeownership levels in SDI populations (and similarly with other priority or target 

populations referenced throughout this plan).

OHSI/HHF Race Reported for All Borrowers:

American Indian or Alaskan Native 1.79%

Asian 2.31%

Black or African American 2.27%

Native Hawaiian or other Pacific Islander 0.66%

White 84.63%

Information Not Provided by Borrower 8.33%

OHSI/HHF Ethnicity Reported for All 

Borrowers:

Hispanic or Latino 8.88%

Not Hispanic or Latino 91.01%

Information Not Provided by Borrower 0.11%

In addition to reporting SDI data based upon representation in the HAF program against the HHF 

data and Oregon’s homeowner and overall population, OHCS may be able to collect data based upon 

the application method used and whether any outreach method was effective. This data would be 

useful in program planning going forward.
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Additional Areas of Interest

OHCS is interested in gathering information on the following:

• The timeline for assistance to be provided to the applicant. This timeline would be measured from the initial 

inquiry point to the initial disbursement of funds (or denial of application, if applicable). OHCS hopes to identify 

application barriers and bottlenecks by monitoring this information.

• The percentage ratio of total applicants who receive assistance and total applicants who were denied for each

program (and each track of the forward payment assistance program). 

• The amount and percentage of Oregon’s overall HAF assistance disbursed to rural and SDI communities, 

including as a representation of homeownership and population across Oregon. 

• The amount and percentage of assistance provided to nontraditional mortgage or lending arrangements.

• Any data about demand, participation, or success that we can obtain and release from the informational 

programming, community outreach and education clinics, and legal aid services aspects of funding.

VIII. READINESS

Hardest Hit Funds Experience

Oregon administered mortgage assistance using the hardest hit funds (HHF), including re-allocation 

of funds recycled from lien payoffs in a covid program that closed June 30, 2021. While these HHF 

programs must wrap up and complete their final audits, Oregon’s HAF team has learned a lot from 

the HHF team. Two members of the HAF team gained nearly 15 years of combined experience in the 

HHF programs and that may increase as HAF continues hiring positions. In addition, when 

conducting stakeholder and public engagement we have solicited feedback on the HHF programs 

and administration, including lessons learned, that will be helpful in setting up HAF programs.

As stated above, Oregon is also engaging in national calls with other states, industry groups, 

servicers, and regulators to determine best practices, improve readiness, and foster uniformity where 

possible. Oregon is also learning from other states with HHF experience.

Pilot Program 

Oregon has received an initial 10% of the state’s HAF allocation and is establishing a pilot program to 

deliver assistance to a narrow segment of borrowers who are most at risk of foreclosure and 

displacement. As described in the prioritization section above, Oregon will attempt to identify 

borrowers in active foreclosure, in pre-foreclosure status, and borrowers with no or limited viable loss 

mitigation options. The agency will solicit, process, and fund applications from these borrowers to

manage capacity and target those homeowners most in need. Oregon’s goal is to open the pilot 

program more broadly in phases and seamlessly transition to the Treasury-approved programs run by 

the program administrator to open the program to all eligible borrowers.
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Oregon’s pilot will help avoid foreclosures while we work internally and with our program administrator 

to build capacity to run the two submitted programs, once Treasury approves them. Existing 

infrastructure will be used during the duration of the pilot program to administer payment processing.

Oregon’s HAF Pilot Program will implement, in substantially the same form, the Mortgage 

Reinstatement and Forward Payment Assistance Program’s as detailed within this plan. Throughout 

the pilot program, data will be monitored to determine if the program terms, caps, eligibility 

requirements, or other details of the program design should be modified. OHCS will maintain 

oversight during the pilot program to assist in the development of best practices and fine tune policies 

and procedures. 

Staffing and Systems

Oregon plans to engage a program administrator for HAF to better manage scalability and technology 

capabilities. OHCS expects to engage this program administrator shortly, for the administrator to have 

sufficient time to learn about Oregon’s programs, develop the technology system, staff a call center 

and processing agents, and test the implementation of the programs. Oregon plans for the program 

administrator to take over from the pilot program in January 2022, which will allow Oregon to

complete its phased opening.

Oregon currently expects to have a HAF staff of nine individuals. Four of these positions have been 

hired and the remainder will be hired between now and January 2022. These employees will conduct 

outreach, monitor the program administrator, review certain approvals and denials, review and 

conduct all denial appeals, coordinate issues with the administrator, servicers, payees, and 

government, as well as conduct payment processing and reconciliation. If the HAF funds are not 

depleted in the initial two programs, this team will evaluate homeowner needs and consider whether 

additional programs are warranted during the HAF program term.

Timeline

Planning

• Perform engagement and outreach and support new and traditional partners in doing the same in their communities. 

• Change and modify program terms, eligibility criteria, and other components based upon updated Treasury guidance, plan 

submission response, national calls, and pilot program experience. 

• Implement legal aid services and informational programming in order to provide information and assistance to homeowners 

prior to opening the main program.

Pilot 

Program

• Launch Pilot Program in November 2021 in phases, initially targeting homeowners most at risk of foreclosure.

• Change and modify program terms, eligibility criteria, and other components based upon updated data gathered during duration 

of Pilot Program.

• Evaluate efficacy of current programs and other servicer and government options. 

Main 

Program 

• Perform program administration testing beginning December 1st. 

• Launch Main Program in January 2022.

• Evaluate efficacy of current programs and discuss necessity of additional programs on a quarterly basis throughout HAF term, 

based upon reports to UST and OHCS. 
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Contracts and Partnerships

OHCS intends to work closely with housing counselors, legal aid attorneys, culturally specific 

community partners, non-profit organizations, vendors, mortgage servicers, tax assessors, other 

qualified payees under HAF, the Oregon Foreclosure Avoidance program, and Oregon’s court 

systems. Subject to evolving needs, Oregon will need contracts for its program administrator, legal 

aid, housing counselors or other intake agencies, outreach clinics, organizations to conduct 

informational programming, a fraud hotline, a service to complete title research, loan signings, and 

recordings, and other services that may not be within the scope of program administration (or have 

not been considered yet). The agency expects to contract with these providers on a pay-forperformance basis. 

IX. BUDGET 

Of Oregon’s $90,937,920 allocation, it is initially allocating 40% to its reinstatement program 

($36,375,168) and 30% to its forward payment assistance program ($27,281,376). With a reservation 

of 15% for administrative costs and 5% for counseling, legal, and education, this leaves some funds 

as a buffer to the extent the pilot program does not allocate a full 10% of the initial funds. This budget 

is subject to change pending evolving requirements or program terms, negotiation of vendors, 

service, and grant awardees, staffing needs and timing, and demand for each of the programs, 

including the pilot program. An estimated projection of the budget based upon the qualified expense 

categories is:

Qualified Expenses

Qualified Expense Mortgage Reinstatement 

Program ($36,375,168)

Forward Payment 

Assistance Program 

($27,281,376)

Total Budget for 

Both Programs

Mortgage Payment 

Assistance (including 

escrowed costs and 

subsequent mortgages)

$0 $23,481,376 $23,481,376

Mortgage Reinstatement 

(including escrowed and 

advanced costs and 

subsequent mortgages)

$28,875,168 $0 $28,875,168

Mortgage Principal

Reduction

$0 $0 $0

Facilitate Mortgage 

Interest Rate Reduction

$0 $0 $0

Utility Assistance $0 $0 $0
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September 28, 2021 32

Internet Service 

Assistance

$0 $0 $0

Homeowner Insurance 

Assistance (separate 

from escrow)

$500,000 $300,000 $800,000

HOA Fees or Liens 

Assistance (separate 

from escrow)

$3,000,000 $2,000,000 $5,000,000

Down Payment 

Assistance Loans 

Assistance

$1,000,000 $500,000 $1,500,000

Property Tax and Lien 

Assistance (separate 

from escrow)

$3,000,000 $1,000,000 $4,000,000

Other Measures to 

Prevent Displacement

$0 $0 $0

Subtotal $36,375,168 $27,281,376 $63,656,544

* This budget does not reflect de minimis payments for some of the $0 budget categories that may 

occur under a program exception or waiver. In addition, these programs are combined to estimate 

each qualified expense category budget on the portal submission, which is why the column at right is 

included here.

Counseling, Education, or Legal Services

Counseling or Educational Services 

$500,000 

Legal Services $1,500,000

Subtotal 

$2,000,000 

Reimbursement of Funds Expended After January 21, 2020

Expense Type $0

Subtotal $0 

Allocation of Administrative Expenses

Instate Travel (outreach clinics, seminars, etc.) 300,300

Office Expenses 37,000

Telecommunications (staff phones) 21,220
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Data Processing (program management costs) 3,675,129

Publicity and Publications (marketing, outreach, 

documents) 345,000

Professional Services (temps; interpretation) 225,000

Intake Assistance 50,000

IT Professional Services (phone conference service) 2,100

Attorney General Legal Fees 20,000

Dues and Subscriptions (constant contact, efax, 

domain, secure email and software license fees) 52,896

Facilities Rent & Taxes (office space) 10,714

Agency Program Related S&S (lien and satisfaction 

recording fees) 787,860

Expendable Property $250-$5000 21,000

IT Expendable Property 21,000

INDIRECT S&S 2,948,665

S&S Total 8,517,884

Personal Services (9 FT staff/benefits 4 yrs. and est. 

indirect time allocations to HAF) 4,811,070

Admin Total 13,328,954

Admin Budget = 15% $13,640,688

* This administrative budget is subject to change based upon changing needs, the rate of program 

deployment, and development with OHCS’ program administrator. The program may wrap up earlier 

than expected or may require agency subsidization.

III. CONCLUSION

OHCS is excited to work with the Treasury, its program administrator, and its vendors, housing 

counselors, culturally specific organizations, and legal aid attorneys to help prevent the foreclosure 

and displacement of eligible Oregon homeowners. Please contact us with any questions or concerns 

about this HAF Plan using the contact information in the Treasury portal. Please find Oregon’s 

submitted Mortgage Reinstatement Program and Forward Payment Assistance Program term sheets 

attached to this HAF Plan.