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HAFP---0112 Puerto Rico Housing Finance AuthorityTreasury Feedback

for Resubmission of Plan

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

Completeness

• Your plan lists Tamara Romero Flores as the Authorized Official, while the original application for HAF 

payments was signed by Francisco Pares. To ensure prompt payment upon approval, the Authorized Official 

needs to be the same as the signatory on the original application for HAF payments. If you need to

establish a new authorized representative for HAF payments, a request should be submitted by email to

HAF@treasury.gov.

Response: Authorized Official has been updated in the portal to designate Ms. Blanca Fernández Gónzalez as the new 

Authorized Official for the HAF Plan.

Homeowner Needs and Community Engagement

Data

• No questions.

Community Engagement and Public Participation

• Your plan indicates that no community-based organizations were engaged in the HAF Plan

development process. Please explain how the program is confident in its ability to reach targeted

populations without engaging such organizations in planning the program design.

Response: The program has a robust outreach plan that includes the distribution of information publicly through 

several media vehicles, including a public facing website. The program will also use direct contact methods such 

as mailers, email, and text campaigns for borrowers referred by mortgage servicers and to lists of potential 

participants provided through Housing Counseling services. The program will engage with community partners 

such as non-profit organizations, municipal figures, and organizations, as well as elected officials to publicize the 

opening of the program, goals/objectives, and availability of assistance.

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

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

Response: With the data compiled by PRHAP Outreach, and engagement with the Mortgage Bankers Association and 

community partners, PRHFA was able to develop a robust communications plan and outreach approach designed to 

engage and facilitate access to low-income communities and reach remote communities, which maybe lacking 

technology resources. As recommended in the public input, PRHFA intends to engage stakeholders and encourage 

community partner buy-in by developing easy-to-implement partner toolkits that encourage program message 

amplification. 

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

Response: There are no Tribes or Tribal entities in Puerto Rico.
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• Please provide an update indicating any public comments you have received since you submitted 

your HAF Plan, from which organization you received any such comment, andwhether you have

responded to the comments.

Response: PRHFA has received no additional public comments since submitting the HAF Plan.

Ongoing Assessment of Homeowner Need

• No questions.

Program Design

• Please explain how the sources of data listed in the section on Homeowner Needs informed theProgram

Design Elements included in your plan.

Response: PRHFA has analyzed demographics, economic conditions, and risk factors for housing instability for Puerto Rico 

at the municipio level. The level of investigation has been determined by the availability of data sources listed in the HAF 

Plan. The goals of the analysis were to identify variation across the island related to housing characteristics and potential 

risk for housing instability and to enable informed, strategic decisions about how to meet the housing needs of 

homeowners while simultaneously achieving the intent of Treasury, as described in the HAF Guidance. Need related to 

mortgage delinquency and associated homeownership costs (taxes, insurance, etc.), and water and electricity are the 

most fundamental to homeowner ability to maintain ownership, avoid displacement, and enjoy stability in a habitable 

environment. The need across these eligible activities outweighs the funding available.

The U.S. Department of Housing and Urban Development (HUD) has issued HAF–specific income limits available at 

https://www.huduser.gov/portal/datasets/haf-il.html. An examination of the income limits for Puerto Rico demonstrates 

that the national median income is greater than the 100% AMI standard across the island; therefore, this will be the 

standard applied for the PRHAP. As such, most Puerto Rican households will also meet this income criterion. Figure 4 

describes the AMI for Puerto Rico in 2021, which ranges from $20,200 to $30,200, with the lowest AMI areas concentrated 

in the west and center of the island and on the municipio islands of Vieques and Culebra to the east. This data was provided 

by the published HUD Income Limit requirements for the HAF program.

Even using the higher income limits of 150% of AMI, per Treasury income-limit requirement, the distribution across Puerto 

Rico municipios ranges between $34,600 and $49,600 below the U.S. median income (also referred to as national median 

income). The U.S. median income for 2021 is $79,900.

Given that the demographic and economic characteristics are more homogeneous across the island than in many mainland 

states, these factors would not be effective weighting criteria in a modeling exercise to determine loan risk. Forbearance 

as an indicator of risk of mortgage default is a concern, with conventional wisdom indicating that those coming out of 

forbearance may automatically fall into an accelerated delinquency rate and/or default status. However, widening loss 

mitigation options are available for homeowners coming out of forbearance. Furthermore, homeowners exiting 

forbearance with mortgage arrearages and without loss mitigation in place will be part of future delinquency counts. 

Therefore, PRHFA has used delinquency as a proxy for loan risk, and therefore need, in each municipio.

The rate of homeownership (owner-occupied housing units) from 2015-2019 is 68.1% with median home value of 

$11,500 for the same time period. Household median income for the period 2015–2019 (in 2019 dollars) is $20,539, 

with per capita income reported at $12,914 and a poverty rate of 43.5%.

Nationally, the mortgage delinquency rate of 7.97% total and 8.65% past due (delinquency plus foreclosure) for singlefamily one- to four-unit residential properties peaked in the second quarter of 2020 and fell to a seasonally adjusted rate 
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of 5.47% of all outstanding loans in quarter two of 2021. Though Puerto Rico’s home loan delinquency rates are also 

trending downward, rates for the same periods were significantly higher than the national average.

Puerto Rico had a residential mortgage delinquency rate of 14.07% by the end of the first quarter of 2020. First quarter 

2021 mortgage delinquency, as reported in the Oficina del Comisionado de Instituciones Financieras (OCIF) 2008–2021 

Mortgage Delinquency Report, indicates that 11.6% (43,743) of mortgages on the island are 30, 60, or 90 days 

delinquent, with the majority (72% or 31,510) of these at the 90-day mark.

The latest data from OCIF’s Loss Mitigation Activity Report provides insight into the breakdown of loss mitigation activity 

in Puerto Rico through April 2021. This report indicates that there are a total of 9,018 mortgage loans in some form of 

loss mitigation, with 59.4% (5,357) in special forbearance due to the moratorium.

PRHFA’s loan servicing portfolio includes only conventional loan types categorized as first and second mortgages. The 

portfolio includes 6,679 total loans, with 41 percent (2,743) in a delinquent status. Of the delinquent loans, 2,315 loans 

are delinquent by 18 months or less (34.7% of the total). The reason the 18-month marker has been chosen as a status 

marker for program data analysis is that Treasury Department Guidance specifically references January 21, 2020, as the 

onset of possible financial consequences of the start of the COVID-19 pandemic. Though 21 months have elapsed since 

January 2020, the most recently available data sources are current through May to July 2021. This provides roughly 18 

months’ worth of information for analysis. 

Assessing the total dollar value of eligible mortgage delinquency by municipio in the PRHFA portfolio, $1,694,122.87 is 

currently outstanding. PRHFA has used this information along with the total months of delinquency for all borrowers 18 

months or less delinquent by municipio to demonstrate delinquency based on total outstanding dollar value and 

number of months delinquent.

The most comprehensive dataset for home loan delinquency is the BlackKnight data that covers approximately 80% of the 

loans in Puerto Rico. BlackKnight used available data to extrapolate its dataset to approximate the full universe of loans 

in Puerto Rico; this extrapolated dataset was used to perform this analysis. Though this dataset does not provide the total 

delinquency amount in dollars, provide a precise count of months delinquent, or distinguish between first and second 

mortgages, it does include delinquency counts in three categories (20–89 days, 90 days or more, and foreclosure) and 

aggregated monthly principal and interest (P&I) for delinquent loans. By multiplying the P&I amounts by the information 

contained within each date range, PRHFA can provide a rough estimate of the average delinquency amount per borrower.

This is important to understand, as this will support projections for average assistance that may be needed by homeowners 

subscribing to the PRHAP.

Using the factors above, PRHFA estimated an average delinquent amount (P&I only, no taxes or insurance) of $6,579.71. 

PRHFA further assumed that the average 30- to 89-day delinquency was an average of two and a half months past due, 

the average 90-day-or-more delinquency was nine months past due, and the average loan in foreclosure was 15 months 

past due. Using this same methodology applied to the BlackKnight dataset, PRHFA can also estimate (by loan type) 

delinquency amounts.

Additionally, PRHFA analyzed rates of delinquency for utility services across Puerto Rico. Though energy costs are 

projected to be lower in the next 10 years for the average household through mass scale improvements to the electric 

system and transition of operation of the transmission and distribution system to LUMA, as well as other structural, 

organizational, and operational efficiencies, the current rate of utility delinquency for homeowners across the island 

remain high. 

Using PREPA’s Financial Report for May 2021, PRHFA was able to roughly approximate average monthly utility cost. By 

taking the total revenue for all residential clients ($113,523,000) and dividing by the average number of clients served 

(1,356,556), the average cost of utilities per month per customer is $83.68. 

There are factors that affect individual customer pricing that vary based on use, energy efficiency, microclimate, etc., 

and many areas and/or individuals likely experience higher rates. However, this estimate provides a starting basis for 
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making assumptions about the potential assistance that may be necessary to support homeowners in arrears.

According to the FOMB Certified 2020 Fiscal Plan for the Puerto Rico Aqueduct and Sewer Authority (PRASA), Fiscal Years 

2021 to 2025, PRASA serves “a population of approximately 3.2 million residents” through the provision of clean water 

and wastewater management, “serving approximately 96% and 50% of the population” with these respective services.

The residential market makes up 95% of the more than 1.2 million active accounts. 

Operating data for PRASA reported for the nine-month period between July 1, 2020, and March 31, 2021, shows that 

residential accounts average water bill, including wastewater management, was $40.82.

This analysis informed the amount of projected average assistance and supported decisions in setting program 

maximums. Please see answer to follow up question later in this document related to method of establishing program 

caps.

• Will there be a method in your HAF program, early in the process of engaging with a household,to evaluate 

immediate threats to the housing stability of applicants, which may need to be addressed under an 

expedited or prioritized timeline (e.g., HOA liens, tax delinquencies, utility shut off)?

Response: The application process is designed to gather information about the applicant’s current housing 

situation. This includes data on the status of mortgage and homeownership costs that can pose an imminent 

threat to housing stability. As a result of the pilot program and findings associated with the pilot applicant 

population, the program application prescreen has been modified to add questions related to immediate threats. 

Applicants answering “yes” to these questions trigger an expedited review. 
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• How will your program leverage resources available through a loss mitigation process to

benefit eligible homeowners and how will your program avoid using HAF funds in ways that 

duplicate relief that available loss mitigation options might provide?

Response: The PRHAP is not currently imposing, and does not intend to impose, any additional eligibility 

requirements related to a homeowner’s status with loss mitigation options. Doing so would be contrary 

to Treasury’s published HAF guidance by placing an additional eligibility burden on homeowners. 

Time is of the essence to avoid foreclosure and eviction. Reinstatement may be necessary before other 

loss mitigation opportunities are fully identified or realized, especially for our most vulnerable 

populations. Therefore, pursuit of loss mitigation, completion of loss mitigation, or deferral of HAF 

assistance until loss mitigation is explored, will not be a requirement under PRHAP in order to receive 

assistance.

Loss mitigation options vary based on a number of homeowner-specific factors to which the servicer 

has access and which the PRHAP does not. Therefore, PRHAP staff cannot appropriately or ethically 

advise as to a homeowner’s specific loss mitigation options. However, PRHAP does recognize the 

importance of loss mitigation opportunities for homeowners. As such, a reference will be made in the 

application process making homeowners aware that there may be other loss mitigation options 

available through their servicers. This will allow homeowners to explore all options available to them 

and make an informed decision about the path which they determine best suits their own needs. PRHAP 

will not interfere with the self-determination of any applicant.

• Your plan indicates that the agency will engage numerous housing counseling 

organizations.Please list those housing counseling agencies with which you anticipate 

contracting or leveraging significant support for homeowners engaged in HAF.

Response:

Provider

Name

Provider

Address

Provider Website Provider Primarily

Serves LMI

Households

Provider

Addresses

Impacts of

Housing

Discrimination

Puerto Rico 

Neighborhood 

Housing 

Services

274 Calle Canals St.

El Ponce Building

Suite 102, Stop 19

San Juan, PR

00907-3052

http://.www.puertoriconhs.org ☒ ☒

CODEVyS 

Corporacion 

para el 

Desarrollo 

económico, 

Vivienda y 

Salud, Inc

PO Box 1800, 

Arecibo, PR 00613

https://www.codevys.com/ ☒ ☐

Pathstone Urb. Paseo Las 

Monjitas, Ponce, PR 

00730

https://www.pathstone.com/ ☒ ☐
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One Stop Career 

Center of PR, 

Inc.

839 Añasco Street, 

Suite 3, San Juan PR 

00925

https://www.onestopcareerpr.org/ ☒ ☐

Consumer 

Credit 

Counseling 

Services of PR

1607 Ponce de León 

Ave.

Cobian's Plaza, GM-9

Santurce, PR 00909

https://www.consumerpr.org/ ☒ ☐

• Please describe how your program will utilize housing counselors or legal services to assist

homeowners in evaluating loss mitigation options available for their mortgage. Your 

descriptionshould include:

o whether your program will connect homeowners with housing counseling or

legalservices early in the process.

Response: Participation in housing counseling services is strictly voluntary and is not required to 

receive assistance through the program. However, homeowners will be provided information for 

housing counseling service providers as a matter of business process in order to seek advice and 

services should the homeowner desire. Program case management staff members will provide 

housing counseling contact information during support sessions for application submission. A link to 

housing counselors is available on our website to help individuals self-select into resources needed.

o the role housing counseling orlegalservices providers will play in supporting

homeowners’ efforts at engaging in loss mitigation.

Response: Housing counseling providers will support homeowners’ efforts at engaging in loss 

mitigation according to their own internal governing procedures, regulations, and processes. 

• Please explain what steps, if any, your program will take to determine whether a HAFresolutionwill result in a sustainable monthly payment for the homeowner?

Response: PRHFA’s HAF program is designed to provide mortgage reinstatement, mortgage payment, 

utility, and associated homeownership cost assistance. As such the program will not result in a 

modification to a homeowner’s monthly payment. However, assistance is intended to provide 

homeowners with financial relief and time. Reinstating delinquent mortgages, paying off past due 

balances for homeownership costs, and providing forward paying mortgage assistance will offer 

homeowners the best chance to catch up on financial obligations and find new opportunities to stay 

current. The program does not intend to monitor homeowner status once benefits are provided and 

the application is closed, as it is not required by Treasury guidance and would constitute an 

administrative burden both in cost and limited staffing resources that would better be used to serve 

additional homeowners.

• Are you anticipating increased winter home energy costs and their potential impact on

the homeowners that HAF will serve?

Response: No. Puerto Rico has a tropical climate with little variation of temperature throughout the 

year.
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• Your programs set $21,0000 as the maximum amount of assistance per homeowner.

Please explain how you determined this amount will be sufficient to resolve housingrelated delinquencies and whether the cap will be sufficient in areas with higher housing

costs?

Response: Need on the island far outweighs the available funding for assistance. With delinquency totals 

well more than $232 million, the Treasury allocation of $75.6 million is roughly 31% of the funding necessary 

to cure all delinquency—and this is just relative to mortgage principal and interest delinquency. These 

figures do not account for insurance, property taxes, homeowner/condominium association fees, liens, and 

common charges, or utilities—all of which are widely known additional financial needs across Puerto Rico. 

With scant data sources available on these other homeownership costs, PRHFA has had to use the 

information that is publicly available, where available, to estimate averages for some of these costs. By 

estimating these costs, the program can create base estimates for total average assistance that may be 

provided to homeowners that can be modified as actual amounts become known through the award 

process.

Currently, PRHFA projects that the average disbursement for each borrower in the planned Reinstatement 

Program plus all other options will be $10,720. The table below provides the numerical summary of the 

information described above for calculating an average PRHAP assistance award.

Breakout of Estimated Average Assistance Award under the

Puerto Rico Homeowner Assistance Program

Assistance Type Estimated Average 

Cost

Mortgage reinstatement (principal and 

interest only) $6,580

Three months payment assistance (3 x 

$710) $2,130

Electricity arrearages (3 x $84) $252

Water arrearages (3 x $41) $123

Other fees (2 x $300) $600

Delinquent property taxes $1,035

Total $10,720

The projected average award value was derived by using the average estimated delinquency of the 

BlackKnight dataset ($6,580 rounded) and the average monthly mortgage delinquency with principal and 

interest ($710 rounded) from Table 8. Assuming an average three-month forward payment of $2,128.53 

(three times the average monthly payment), assistance for mortgage reinstatement and future payment 

assistance totals $8,708.24.

Assuming every homeowner who receives assistance is also three months behind on electric utilities—an 

average delinquency of $84 per month—the projected average assistance for this benefit option would be 

$252. Using information from PRASA’s most recent quarterly financial report, PRHFA knows that the average 

water bill across the island is $41. Again, assuming a three-month delinquency, this would result in an 

average benefit amount of $123 for water and sewerage arrearages.

As there were no data available on delinquent homeowner/ condominium or other associated 
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homeownership fees, an allowance of an average of $300 per homeowner has been included. Assuming that 

this is a yearly rate and that arrearages are owed for 2020 and 2021, this would bring the total average 

benefit for delinquent homeowner/condominium fees to $600. 

Property taxes in Puerto Rico are collected at the state level and distributed to the 78 municipios. The agency 

responsible for property tax collection is Centro de Recaudacion de Ingresos Municipales (CRIM). The 2021 

Fiscal Plan projects real property tax revenue at $677 million for Fiscal Year (FY) 2021, which includes 

residential, commercial, industrial, vacant and other property types. There are an estimated 1,065,375 

residential properties, which make up 81.4% of the total properties. Tax rates vary across the island by 

municipio from 8.0% to 12.99%.1 Taxes are collected bi-annually, due on January 1 and July 1 each year. All 

municipios across Puerto Rico exhibit a low collection rate compared to mainland counterparts. In FY 2020, 

collection rates for real property ranged from 78% to a low of 39%. CRIM estimates that low collection rates 

“have generated a large gross accounts receivable balance amounting to $1.7 billion in principal and $1.9 

billion in interest and penalties (net of discounts) at the end of FY2019”. However, after applying a reserve 

against gross accounts receivable, the net figure falls to $660 million.

Though there is no published data on the average cost of property taxes, PRHFA can deduce a rough average 

yearly tax amount per taxable residential property by first multiplying the residential structure percentage 

of 81.4% by the projected FY 2021 real property tax revenue to yield an estimate of the proportion of real 

property tax revenue attributed to residential structures ($551,078,000). By dividing this number by the 

number of estimated residential properties, this provides an estimated average yearly property tax amount 

of $517.26 per residential property. Assuming that the eligible property taxes are owed for 2020 and 2021, 

this would bring the average property tax benefit under PRHAP to $1,034.52.

Using the total estimated average assistance award amount and an assumed allocation budget after

administration and planning costs are deducted, and after funding for housing counseling services are 

deducted, the PRHAP Pilot and full program would have $61,871,509.36 available for homeowner funding 

to disburse to roughly 5,771 Puerto Rico homeowners in need. These are initial base projections and will be 

modified over time as real award values are able to be taken into consideration. PRHFA will make every 

effort to minimize administration and planning costs which, if successful, will result in additional funding 

being made available to the project delivery budget. Any increase in the project delivery budget will result 

in an increase of funding availability directly to homeowners in need.

PRHFA used the most recent available data sources when conducting the initial needs assessment in 

July/August 2021. Much of that information was already dated by several months, with no updated data 

available. Since initial plan submission, additional time has now passed and PRHFA has assumed that need 

has grown. With uncertainty as to the timeline of final plan approval, PRHFA also had to account for an 

unknown number of additional months which homeowners may accumulate additional delinquencies. 

PRHFA used the needs assessment analysis to yield a best guess at average assistance homeowners need 

across the island. To account for variance on the higher end of potential delinquency and the accumulation 

of additional delinquency pending full program roll out, PRHFA doubled the average expected benefit to 

account for these factors. 

As the program moves forward, PRHFA will monitor the actual award average, as well as high-end outliers, 

to examine whether the cap is sufficient to accommodate most eligible homeowner situations, or it should 

be adjusted.

1 Ibid, p. 16.
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Eligibility

• No questions.

Outreach

• Please explain how the program willtarget outreach and provide accessto homeowners with

limited proficiency with English and Spanish.

Response: The communications strategy focuses on the development and successful implementation of the 

PRHAP’s goals of accessible marketing, intake operations, and leveraging program champions. As Spanish is 

the predominant language spoken in Puerto Rico and most available advertising and marketing media 

outlets are Spanish outlets, all program materials, advertising, and assistance will be provided in both 

Spanish and English. We ensure that materials are culturally appropriate for Spanish-speakers from Puerto 

Rico. Call center and case management services are provided primarily by bi-lingual staff members as well 

as single language speakers of both Spanish and English. We have a proven strategy to overcome 

communication barriers, ensuring bilingual communication for customer service at all times.

Prioritization

• No questions.
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Performance Goals

• Please provide any update to the preliminary performance goals you included in you plan.

Response: There have been no revisions to the initial performance goals submitted.

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

the public.

Response: PRHFA will publish reports and other status communications to the public-facing 

website.

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

yourprogram.

Response: Number of homeowners assisted through mortgage reinstatement and forward paying 

mortgage assistance. Number of homeowners served through tax delinquency assistance.

Number of homeowners served through utility assistance.

• Please consider including as an additional metric the number of homeowners

assisted/foreclosures prevented solely through counseling or legal services without payment of

HAF funds to resolve the homeowner’s defaults or delinquencies.

Response: Homeowners who do not receive HAF funding are generally not trackable by the program. 

This is because homeowners who do not engage with the program are an unquantifiable and 

unidentifiable population. Further, for those that do engage, but do not receive assistance due to failure 

to participate, withdrawal, or ineligibility, the program typically loses ability for further communication 

as these individuals become unresponsive. However, since PRHFA will be funding housing counseling 

services through HAF expenditures, PRHFA will request statistics from counseling providers related to 

number of homeowners assisted/ foreclosures prevented through their services as part of the grant 

agreement established with these service providers. PRHFA will report on the applicant numbers and 

outcomes demonstrated by the housing counseling services as a result of the subrecipient reporting 

requirements.
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Readiness

• Please provide the most recent available information about your program'sreadiness,

includingstaffing, contractors, etc.

Response: PRHFA has established its own internal management control structure for overseeing the 

HAF program. PRHFA has also contracted with a vendor to provide implementation support that 

includes a call center, case management services, an online application portal, and eligibility and 

payment services.

The program has established overarching policies and procedures. Further, task level activities 

necessary for outreach, intake, eligibility, quality control, CDF transmission, and payment have been 

developed, including standard operating procedures for each. Staff training on program rules, process 

workflows, systems, and tools is conducted at staff onboarding and on an ongoing basis. Staffing levels 

will be monitored and ramped up or down based on volume of applications. PRHFA has three physical 

site locations to support applicants in addition to the existing remote support services.

PRHFA is running a pilot program that is open to applicants today. Through operation of the Pilot 

Program, PRHFA is identifying process bottlenecks and policy gaps, formulating resolution, and 

implementing changes to address them. These program improvements are intended to create a system 

ready for full operation when Treasury approves the HAF Plan. 

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

tolaunch following approval?

Response: PRHFA believes that the PRHAP is ready for launch as soon as approval is received. 

PRHFA is confident that the necessary infrastructure for full program launch is in place, policies and 

procedures have been developed, systems are functional to handle increased volume of 

applications, plans have been activated to ensure appropriate staffing levels at all times, and 

controls are in place to support anti-fraud, waste and abuse protocols. 

• Please provide updated information about your progress in spending the initial 10% 

paymentfrom your jurisdiction’s full allocation and the status of any pilot assistance already 

offered ormade available to homeowners.

Response: To date, the total costs associated with the needs assessment and plan development, pilot 

design and launch, and associated administrative activities is approximately $276,703.00. The statistics 

on the pilot program are updated below:

Number of households that have applied for assistance: 325

Number of households that have received funding: 32

Amount of funding disbursed: $101,721.73

Number of households potentially eligible and estimated dollar value, pending final eligibility 

and/or CDF confirmation: 64 potentially eligible households, $130,000.00. 40 households 

pending CDF confirmation and 57 households pending Initial Eligibility Approval****Note 

that results of CDF process could change eligibility status and funding totals.
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Budget

• No questions.