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HAF Grantee Plan - HAFP-0147 -Oklahoma Housing Finance Agency - Extracted 02/15/2022 22:04:49

United States Department of the Treasury

Homeowner Assistance Fund Plan

Submitted by Oklahoma Housing Finance Agency

HAF Grantee Plan Name

HAFP-0147
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United States Department of the Treasury

Homeowner Assistance Fund Plan For Participants 

with Allocations $5 million or Greater

Allocation Amount $5 Million or Greater

Submission Date 12/21/2021 12:26 PM

Total Plan Requested Amount $87,056,967.00

Record Type State

Application Record SLT-0087

HAF Grantee Plan Status (external) Funded
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Homeowner Needs and Community Engagement

What Quantitative Data Has Informed the Participant’s Planning?

Treasury will assess the extent to which a Participant has, in the course of its HAF planning process, relied on

quantitative data, including from community-based organizations or organizations that serve potentially

eligible homeowners. 

In its HAF planning process, has the Participant obtained quantitative data from mortgage servicers, private

data providers, government entities, community-based organizations, or other sources to inform its planning

about how to target and best serve eligible homeowners with mortgage delinquencies, defaults, foreclosures?

Yes

If yes, please list and, briefly describe each source of quantitative data.

Data provided by Treasury – Treasury provided data, contributed by a number of federal

agencies, including information on mortgage delinquencies and forbearances, breakdowns by

demographic factors, and concentration among mortgage servicers.

Data from Mortgage Servicing - OHFA has obtained a schedule of delinquent mortgages from

OHFA's master servicer.

In its HAF planning process, has the Participant obtained and reviewed quantitative data or studies regarding

which demographic segments in its jurisdiction have historically experienced discrimination in the housing or

housing finance market?

Yes

If yes, please list and, briefly describe each source of quantitative data.

Oklahoma Department of Commerce Analysis of Impediments to Fair Housing Choice prepared

in support of Oklahoma's Five-year state consolidated plan April 1, 2019 through March 30,

2023.

In its HAF planning process, has the Participant obtained quantitative data from utility providers or entities

charged with assessing and collecting property taxes or relied on quantitative data or studies to inform its

planning about how to target and best serve eligible homeowners at risk of displacement due to utility

arrearage or tax foreclosure?

No

In the following text box, please list any source not listed above of quantitative information, including

sources of data on the performance of any of the Participant’s previously implemented programs, that the

Participant used to inform its HAF planning process, briefly describe how the data informed the Participant’s

planning.

N/A
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Did the Participant communicate with mortgage servicers regarding the development of its program design?

Yes

Did the Participant communicate with other HAF participants regarding the development of its program

design?

Yes

How Has Community Engagement and Public Participation Informed the

Participant’s Planning?

Treasury will assess the extent to which a Participant’s assessment of homeowner needs has been informed

by and reflects input from organizations and individuals representing eligible homeowners, including any

opportunities for public participation in the development of the Participant’s plan. Treasury will pay

particular attention to the extent of the Participant’s engagement with populations that are the subject of

statutory targeting requirements.

Has the Participant requested and received input on its HAF planning process from providers of housing

counseling services or providers of legal assistance to homeowners facing foreclosure or displacement?

Yes

Provider information

If yes, please list such providers, including the providers’ address and website. Please indicate by checking

the appropriate box below if the provider’s primary purpose is to serve low- and moderate-income

households or to address the impacts of housing discrimination on one or more demographic groups in the

Participant’s jurisdiction.

Provider Name 

Provider Address 

Provider Website

Provider

Primarily

Serves

LMI

Households

Provider

Addresses

Impact of

Housing

Discrimination

Legal Aid Services

3800 N. Classen Blvd ,Oklahoma City,Oklahoma 73118

http://www.legalaidok.org

Metropolitan Fair Housing Council

312 NE 28th St #112 ,Oklahoma City,Oklahoma 73105

http://www.metrofairhousing.org

Has the Participant requested and received input regarding its HAF planning process from community-based

organizations or organizations that serve potentially eligible homeowners?

Yes

Community Information
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If yes, please list such organizations, including the providers’ address and website if available. Please

indicate by checking the appropriate box below if the provider’s primary purpose is to serve low- and

moderate-income households or to address the impacts of housing discrimination on one or more

demographic groups in the Participant’s jurisdiction.

Organization Name 

Organization Address 

Organization Website

Organization

Primarily

Serves LMI

Households

Provider

Addresses

Impact of

Housing

Discrimination

Urban League of Greater Oklahoma City

3900 N. Martin Luther King Jr. Avenue, Oklahoma City, Oklahoma

73111

http://www.urbanleagueok.org

Latino Community Development Organization

420 SW 10th, Oklahoma City, Oklahoma 73109

http://www.lcdaok.com

Has the Participant consulted with localities or tribal governments (cities, counties, or rural communities) in

its jurisdiction regarding the needs of eligible homeowners in its jurisdiction?

Yes

Has the Participant provided an opportunity for public input regarding its HAF Plan through public hearings

or published materials?

Yes

If yes, please indicate whether a proposed or draft plan was published, please describe where details about the

comment solicitation were posted, for how long, in what languages, and whether any efforts were made to

make the posting accessible to persons with disabilities or individuals without reliable internet access.

The draft HAF plan was published on June 14th, 2021 and public comments were accepted via

email through June 23rd. The draft HAF plan was discussed at an in-person public input session

held June 24 regarding emergency housing needs. The draft plan was published on the OHFA

website which is available in English, Spanish, Vietnamese, Chinese, Filipino, German, Japanese

and Thai. The entire OHFA email database, including numerous community-based organizations

were informed of this publication so they could inform the communities they serve.

How Will the Participant Continue to Assess the Needs of Eligible

Homeowners?

Treasury anticipates that an ongoing process of assessing the needs of eligible homeowners will help address

the needs of potentially eligible homeowners as economic conditions change over time.

Does the Participant plan to update its assessment of community needs within the next year to determine

whether its HAF program design should be updated to address changing needs of potentially eligible

homeowners?
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Yes

What additional data would be helpful to the Participant as it seeks to assess homeowner needs over time?

Monthly data from servicers;

Continued updates from Treasury and other federal agencies, including information on

mortgage delinquencies and forbearance, breakdowns by demographic factors and concentration

among mortgage servicers;
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Program Design

What are the Program Design Elements Through Which the Participant Will

Deliver HAF Assistance to Eligible Homeowners?

A program design element is a specific activity or program, which is consistent with a qualified expense

category, under which a Participant will disburse HAF funds in accordance with the HAF Plan. Please note

that multiple program design elements may fit under a single qualified expense category; for example, a

mortgage assistance program that has different terms for federally backed mortgages and manufactured-home

mortgages may constitute two separate program design elements, for which case the Participant provides a

separate term sheet or other description for each program design element. 

HAF participants must have at least one program design element intended to reduce mortgage delinquency

among targeted populations. Treasury encourages HAF participants to consider program design elements that

address homeownership preservation for targeted populations in areas where there is a sustained trend of

increasing property taxes or utility costs, including for households that do not have mortgages.

Please identify each qualified expense category in which the Participant will offer a program design element

by checking the boxes below.

mortgage payment assistance 

 mortgage principal reduction, including with respect to a second mortgage provided by a nonprofit

or government entity 

 payment assistance for homeowner’s utilities, including electric, gas, home energy, and water 

 payment assistance for homeowner’s insurance, flood insurance, and mortgage insurance 

 payment assistance for delinquent property taxes to prevent homeowner tax foreclosures 

 payment assistance for down payment assistance loans provided by nonprofit or government

entities 

 financial assistance to allow a homeowner to reinstate a mortgage or to pay other housing-related

costs related to a period of forbearance, delinquency, or default 

facilitating mortgage interest rate reductions 

 payment assistance for homeowner’s internet service, including broadband internet access service,

as defined in 47 CFR 8.1(b) 

 payment assistance for homeowner’s association fees or liens, condominium association fees, or

common charges 

 measures to prevent homeowner displacement, such as home repairs to maintain the habitability of

a home or assistance to enable households to receive clear title to their properties 
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For each program design element that the Participant will offer, the Participant is required to upload a term

sheet or other description, that, at a minimum, provides the following information regarding that program

design element. Term sheets for all of Participant’s HAF programs may be uploaded together as one

document.

Title Upload

Date

OHFA HAF Mortgage Payment Assistance Program Term Sheet 12.3.21 HAF Dec

resubmission

12/3/2021

2:53 PM

OHFA HAF Government or Nonprofit Down Payment Loan Reinstatement Program Term

Sheet 12.3.21 HAF Dec resubmission

12/3/2021

2:53 PM

HAF Resubmission of Plan Treasury feedback responses Dec 2021 12/3/2021

3:19 PM

OHFA HAF Mortgage Reinstatement Program Term Sheet 12.3.2021 HAF Dec

resubmission

12/3/2021

2:53 PM

OHFA HAF Non-escrowed Property Charges Program Term Sheet 12.3.2021 HAF Dec

resubmission

12/3/2021

2:53 PM

Income-Proxy Eligibility and Income Verification Requirements for HAF - Rev 12-3-10 12/3/2021

3:21 PM

A HAF participant may elect to revise its HAF Plan over time to add or subtract program design elements.

Does the Participant anticipate adding additional program design elements to this HAF Plan within one year

of this submission?

Yes

Treasury has provided sample term sheets to assist HAF participants in developing their HAF plans.

Participants may use these sample term sheets, in whole or in part, as part of their submission. To the extent

the Participant intends to structure the program differently with respect to significant program terms

described in the Sample Term Sheets, Treasury will, in the course of its review of the HAF Plan, request a

justification for how the alternate approach will further the objectives of the HAF, including targeting and

prioritization requirements. In the chart below, the HAF Participant may provide a justification for significant

deviations from the terms described in the sample term sheets upon initial submittal. (optional for initial

submission)

Program

Design

Element

Deviation from sample

terms Justification

Required

loss

mitigation

waterfall

prior to

HAF

OHFA will not require

homeowners to go through

a loss mitigation waterfall

prior to using HAF.

Loss mitigation waterfalls are a barrier that would

significantly delay providing vital assistance to homeowners.

OHFA is concerned that lenders may not have the staff or

resources to perform these reviews timely.
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Documentation of Homeowner Income

Homeowners are eligible to receive amounts allocated to a HAF participant under the HAF only if they have

incomes equal to or less than 150% of the area median income or 100% of the median income for the United

States, whichever is greater. In addition, not less than 60% of amounts made available to each HAF

participant must be used for qualified expenses that assist homeowners having incomes equal to or less than

100% of the area median income or equal to or less than 100% of the median income for the United States,

whichever is greater. The HAF guidance describes permissible ways for HAF participants to determine

homeowner income.

Under the HAF guidance, one permissible approach for determining income is for (1) the household to

provide a written attestation as to household income and (2) the HAF participant to use a reasonable

fact-specific proxy for household income, such as reliance on data regarding average incomes in the

household’s geographic area. Will the Participant allow income to be determined in this way?

Yes

If yes, please describe the fact-specific proxy or proxies to be used for the income determination.

Program Income Eligibility

Oklahoma Housing Finance Agency will determine income eligibility for the program based on

applicants with household incomes at or below the greater of 100% of the US Area Median

Income (AMI) or by county by household size.

For individuals who identify as socially disadvantaged, OHFA will determine income eligibility

for the program based on applicants with household incomes at or below the greater of 100% of

the US Area Median Income (AMI) or 150% Area Median by county by household size.

Fact-Specific proxy Eligibility for Income Verification

Oklahoma Housing Finance Agency is using a fact-specific proxy to reduce documentation

requirements to remove barriers and expedite payments on behalf of Oklahoma homeowners.

Applicant households with self-reported incomes of greater than or equal to 100% Area Median

Income (AMI) for their county for a four-person household size will not be able to use the

fact-specific proxy and will have to submit additional income documentation.

Under the HAF guidance, HAF participants may provide waivers or exceptions to this documentation

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

practical challenges related to the pandemic, or a lack of technological access by homeowners; in these cases,

the HAF participant is still responsible for making the required determination regarding household income

and documenting that determination. Will the Participant allow applicants to request such waivers or

exceptions?

Yes

Eligible Mortgage Types

Please indicate which of the following mortgage types are eligible to be assisted under one or more of the

Participant’s program design elements.

 First Mortgages 

 Reverse Mortgages (Home Equity Conversion Mortgages, Single-Purposes Reverse Mortgages, or

Proprietary Reverse Mortgages) 
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 Contracts for Deed or Land Contract (if it is a credit transaction secured by a consensual security

interest in a dwelling) 

 Second Mortgages 

 Loans Secured by Manufactured Housing (secured by real estate or dwelling) 

If the Participant excludes any of the forgoing mortgage types from one or more program design elements,

explain the exclusion.

Reverse mortgages have no monthly payment to make other than possibly real estate taxes,

property insurance, and HOA dues which would be eligible under the OHFA Non-escrowed

delinquent property taxes, insurance premiums, HOA, and condominium fees program.

Contracts for Deeds would not be conforming loans and could present much higher opportunities

for program fraud and abuse through related party transactions.

How Will the Participant Target HAF Resources Consistent with Statutory

Requirements? 

The Participant must describe how it will target HAF resources in accordance with the HAF guidance.

Targeting strategies are affirmative efforts to inform, encourage the participation of, and facilitate access to

resources for targeted households, including by offering multiple intake formats, engaging with nonprofit

organizations (e.g., housing counselors or legal services organizations) to provide additional pathways into

the program, and providing community outreach, partnerships with housing counseling agencies or legal aid

organizations, or other educational services that are aligned with the HAF participant’s program design, in a

manner that is culturally and linguistically relevant to the targeted communities.

Defining Socially Disadvantaged Individual

Please describe the process the Participant will use to determine whether a homeowner is a “socially

disadvantaged individual” as defined in the HAF guidance.

OHFA will rely on applicant self-certification for determining whether a homeowner is socially

disadvantaged as defined in the HAF guidance in order to not place additional roadblocks.

Public Communications

Will the Participant engage in a public communications campaign to raise awareness among targeted

populations about the availability of HAF resources, in media such as television, newspapers, online media,

or social media?

Yes

If yes, please indicate whether the public communications campaign will include communications that

primarily target the following populations:

 Homeowners earning less than 100% of area median income 

 member of a group that has been subjected to racial or ethnic prejudice or cultural bias within

American society; 
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 resident of a majority-minority Census tract; (3) 

 resident of a U.S. territory, Indian reservation, or Hawaiian Home Land 

 homeowners in persistent poverty counties; 

 individual with limited English proficiency 

Please indicate in which languages, in addition to English, public communications to targeted populations

will be undertaken:

Spanish; Vietnamese

Outreach

Will the Participant engage in outreach through partnerships with organizations that focus primarily on

serving homeowners earning incomes below 100% of area median income or socially disadvantaged

individuals and that have the capacity to engage targeted communities in a culturally and linguistically

relevant manner to encourage the submission of applications for HAF resources from targeted populations?

Yes

If yes, please indicate whether the community outreach efforts will include partnerships with organizations

that primarily target the following populations:

 member of a group that has been subjected to racial or ethnic prejudice or cultural bias within

American society; 

 resident of a majority-minority Census tract; (3) individual with limited English proficiency; 

 resident of a U.S. territory, Indian reservation, or Hawaiian Home Land;

 homeowners that reside in persistent poverty counties; 

 individual with limited English proficiency. 

Housing Counseling and Legal Services

Will the Participant facilitate access for eligible households to housing counseling or legal services?

Yes

If yes, please identify below the providers of housing counseling or legal services that have indicated to the

Participant that they are willing and able to support homeowners receiving assistance under the Participant’s

HAF programs. 
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Provider Name 

Provider Address 

Provider Website

Provider

Primarily

Serves

LMI

Households

Provider

Addresses

Impact of

Housing

Discrimination

Legal Aid Services of Oklahoma

3800 N. Classen Blvd; Ste 230 , Oklahoma City, Oklahoma 73118

http://www.legalaidok.org

Metropolitan Fair Housing Council

312 NE 28th Street #112 , Oklahoma City, Oklahoma 73105

http://www.metrofairhousing.org

Neighborhood Housing Services

4101 N. Classen Blvd, Ste A , Oklahoma City, Oklahoma 73118

http://www.nhsokla.org

Targeting specific groups of homeowners

Will the Participant conduct outreach specifically tailored to target potentially eligible households that:

 have mortgages or mortgage assistance contracts held or backed by the Participant? 

 have mortgages backed by any of the following agencies: Federal Housing Administration;

Department of Veterans Affairs; U.S. Department of Agriculture? 

 have privately held mortgages? 

What Efforts will be Made to Address Barriers to HAF Program Participation for

Potentially Eligible Homeowners, Including Those with Limited English

Proficiency or Who are Disabled?

Targeted outreach may be needed to reach homeowners who are likely to experience barriers to access,

including persons with limited English proficiency and those with disabilities.

Indicate all of the languages, in addition to English, in which the Participant’s HAF application and other

program documents will be made available.

Spanish; Vietnamese

Will the Participant’s HAF applications and other program documents be provided in forms that are

accessible to persons with disabilities?

Yes
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Performance Goals

Treasury will consider the goals and benchmarks the Participant proposes to use to measure the effectiveness

of its programs, including whether those goals address the homeowner needs identified by the Participant, the

extent to which the goals are disaggregated by key homeowner characteristics as appropriate for the

jurisdiction, and whether they include a goal focused on reducing mortgage delinquency.

Please describe Participant’s goals and benchmarks for each of its programs with the following program

design elements.

Program Design

Element Metric of Success Goal

Mortgage Payment

Assistance

number of home

losses avoided due to

HAF funding

assist 5100 homeowners with up to 3 mortgage

payments

Payment Assistance

for Delinquent

Property Taxes

number of home

losses avoided due to

HAF funds

prevent the displacement of 2500 homeowners by

assisting with delinquent property taxes

Mortgage

Reinstatement

number of home

losses avoided due to

HAF funds

assist 5100 families to prevent displacement by catching

up mortgage and escrow payments in arrears

Payment Assistance

for Down Payment

Assist. Loans

number of home

losses avoided due to

HAF funds

assist 100 homeowners to avoid possible foreclosure due

to past due payments on loans provided by government

or non-profit entities

Payment Assistance

for Homeowner’s

Insurance

number of uninsured

houses avoided due to

HAF funds

keep 1500 hundred homeowners insured

Payment Assistance

for HOA fees or liens

number of home

losses avoided due to

HAF funds

assist 100 homeowners to avoid possible foreclosure due

to possible homeowner association liens
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Readiness

Staffing, Systems and Contractors 

Treasury seeks information regarding the Participant’s organizational capacity to implement its HAF Plan.

Does the Participant anticipate needing to hire additional staff to implement this HAF Plan?

Yes

Does the Participant anticipate significant information technology system upgrades to implement this HAF

Plan?

Yes

Does the Participant have policies or procedures that govern the implementation of each HAF program

design element described in this HAF Plan?

No

If no, is a policy and procedure in development for each HAF program design element described in this HAF

Plan?

Yes

Will the Participant use HAF funds to assist eligible households through a program that was operational

before the Participant first received HAF funds?

No

Will the Participant use any third-party contractor or partner to conduct program administration (such as

reviewing applications, determining eligibility, processing payments, conducting reporting, and reviewing

compliance) for some or all of the Participant’s HAF programs?

No

Use of Initial Payment

If the Participant has already received any HAF funds from Treasury, provide the following information

about the use of such funds as of June 30, 2021.

What amount of the HAF funds that the Participant has received been disbursed to eligible homeowners?

$0.00

Has the Participant begun accepting applications from homeowners for any HAF-funded programs?
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No

How much of the HAF funds that the Participant has received been obligated?

$0.00

Provide a brief description of how the Participant has used the HAF funds it has received.

OHFA has received zero funds as of 9/29/21.
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Budget

Budgeting of HAF Funds by Program Design Element 

Specify the amounts of HAF funds that the Participant proposes to allocate to each of the following program

design elements, if offered:

Measure Amount

Mortgage Payment Assistance $23,000,000.00

Mortgage Principal Reduction $0.00

Payment Assistance for Homeowner’s Internet Service $0.00

Payment Assistance for HOA fees or liens $100,000.00

Payment Assistance for Delinquent Property Taxes $3,500,000.00

Mortgage Reinstatement $41,778,422.00

Facilitate Mortgage Interest Rate Reduction $0.00

Payment Assistance for Homeowner’s Insurance $2,500,000.00

Payment Assistance for Down Payment Assist. Loans $120,000.00

Payment Assistance for Homeowners Utilities $0.00

Other measures to prevent homeowner displacement

Measure Amount

None $0.00

Displacement Prevention Sub-Total $70,998,422.00

Counseling or Legal Services

The Participant may allocate up to 5% of its HAF funds for counseling or educational efforts by housing

counseling agencies approved by the Department of Housing and Urban Development or a tribal government,

or legal services, target to households eligible to be served with funding from the HAF related to foreclosure

prevention or displacement.
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Specify the Participant’s allocations for the following Amount

Counseling or Educational Services $3,000,000.00

Legal Services $0.00

Services Sub-Total $3,000,000.00

Reimbursement of Funds Expended After January 21, 2020

As described in the HAF guidance, HAF funds may be used for reimbursement of certain expenses between

January 21, 2020 and the date when the first HAF funds are disbursed by the HAF participant under the HAF

for a qualified expense (with certain limitations, as set forth in the HAF guidance).

Type of Expense Amount

None $0.00

Reimbursement Sub-Total $0.00

Allocation of Administrative Expenses

Type of Expense Amount

salary, taxes, insurance, & retirement $6,904,000.00

Software fees $775,000.00

Contract labor $622,000.00

Legal $135,000.00

Office Rent $388,000.00

Training and Travel $120,000.00

Postage and related $135,000.00

Advertising $125,000.00

Telephone $108,000.00

Other General & Administrative (including mileage, audit, office supplies,

dues/subscriptions, printing, copier, bank service fees, general insurance, D&O insurance,

and miscellaneous expenses).

$454,758.00

HHS approved indirect cost rate (currently 66.7% of direct labor) $3,291,787.00
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Administrative Expenses Sub-Total $13,058,545.00

Total Plan Requested Amount $87,056,967.00

Amount Requested Confirmation:

Yes
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Contacts

Please identify up to three contacts for the Participant- a primary contact, a designated point of contact for

reporting, and an additional contact.

Primary Contact

Name: Valenthia Doolin

Agency/Office: Oklahoma Housing Finance Agency

Email: valenthia.doolin@ohfa.org

Phone Number: 4054198156

Reporting Contact

Name: Kurt Fite

Agency/Office: Oklahoma Housing Finance Agency

Email: kurt.fite@ohfa.org

Phone Number: 4054198212

Additional Contact

Name: Deborah Jenkins

Agency/Office: Oklahoma Housing Finance Agency

Email: deborah.jenkins@ohfa.org

Phone Number: 4054198290

Proprietary or Otherwise Non-Public Information

Does your plan submission include any information or materials that are proprietary or otherwise non-public?

No

If "Yes," please indicate which information or materials are proprietary or otherwise non-public.
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Title VI Assurances

You must provide on behalf of the HAF Participant assurances that the HAF Participant will comply with

Title VI of Civil Rights Act of 1964. Please download the assurances, then review, sign, and upload the

signed copy to this page before submitting the HAF Plan.

Title Upload Date

6. HAF-Title VI Assurance (5-18-2021) signed 9/28/2021 7:45 PM
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Official Certification

I (the undersigned) certify that the information provided in the HAF submission is accurate and complete

after reasonable inquiry of people, systems, and other information available to the HAF Participant. The HAF

participant and I acknowledge that any materially false, fictitious, or fraudulent statement or representation

(or concealment or omission of material fact) in this submission may be the subject of criminal prosecution

under the False Statements Accountability Act of 1996, as amended, 18 U.S.C. § 1001 and also may subject

me and HAF Participant to civil penalties and/or administrative remedies for false claims or otherwise,

(including 31 U.S.C. §3729 et seq.). I am an authorized representative of HAF Participant with authority to

make the above certifications and representations on behalf of the HAF Participant.

Name of HAF Participant:

Oklahoma Housing Finance Agency

Name and Title of Certifying Official

Name: Deborah Jenkins

Title: Executive Director

Telephone: 4054198290

Email: deborah.jenkins@ohfa.org