Proposed Washington State HAF Plan

Treasury Questions and WSHFC Responses

Exhibit A

Public Comment Received
Bill Rumpf

Chair

Steve Walker

Executive Director

1000 Second Avenue, Suite 2700, Seattle, WA 98104

Tel: 206-464-7139| 800-767-4663 | Fax: 206-587-5113 | wshfc.org

Below are the comments we have received through 12:00 pm, Tuesday, March 22, 2022 regarding the 

Proposed Homeowner Assistance Fund Plan scheduled for Public Hearing at your meeting on Thursday, 

March 24, 2022. These materials supplement Tab Number 3 in your meeting packet.

Comments were gathered by allowing interest parties to email the Commission (HAF@WSHFC.ORG), at 

our public comment meeting on March 16, 2022 or via a survey on our website. 

Via Survey; General 

Comments:

"As Executive Director of the Washington Homeownership Resource Center and 

someone who was actively working on behalf of struggling homeowners during 

the Great Recession, I have experience with helping distressed homeowners. I 

commend the WSHFC on a well-thought and thorough plan for homeowner 

relief. In particular, I appreciate the dedication to partnership and listening that 

Commission staff displayed as they developed this plan. Our foreclosure 

prevention partnership - Hotline, counseling, legal aid, and mediation - has 

been tested and proven effective. Relying on the strengths of this network will 

leverage the ARPA resources as effectively and efficiently as possible while 

ensuring as many homeowners as possible can be helped back on their feet 

post-forbearance or post-hardship. I look forward to continued partnership 

once the plan is approved to implement the program and deliver these much 

needed services."

Staff Perspective: Comment received. 

Via Survey; General 

Comments:

"Use the funds to eradicate homelessness so use the funds to get the homeless 

people ,medical help psychological help . There a lot of abandoned homes I see 

buy those and make it easy for those in the lower income level to move in . A 

lot of of commercial buildings are empty buy those building and convert to 

living spaces for low income familys Increase the down payment assistance 

amount since rates have gone up and ratios and not getting higher increase the 

amount. You can start a program like other states that forgive the down 

payment program if the refinance and sale conditions are followed ."

Staff Perspective: Comment received. 

Via Survey; General 

Comments:

"From my initial reading of the Proposed Plan, I am unsure if the funding is for 

existing homeowners, or is intended to make new homeowners. The down 

payment assistance, as an eligible use, seems to suggest that this is not entirely 

a foreclosure prevention/anti-displacement tool for those who have sustained 

financial hardship in continuing their home ownership due to conditions 

beyond their control."

Staff Perspective: The proposed program is for existing homeowners.
Proposed HAF Plan Comments – Through Noon on March 22, 2022

Page 2

Via Survey; 

Program Eligibility:

"I support these eligibility requirements and believe they will help the funds 

reach those most in need of assistance."

Staff Perspective: Comment received.

Via Survey; 

Program Eligibility:

"What is meant by "reasonable expectation"? Will there by any follow-up to 

determine if the homeowner has been able to bring all arrearages current? Or if 

the homeowner has continued to make mortgage payments?"

Staff Perspective: Will be developed as a part of the program guidelines.

Via Survey; 

Program Eligibility:

"Homeowner should have banks statements reviewed for income & spending 

habits. Several people came to me for cash out refinances while in forbearance 

and as I did a thorough review of the bank statement they had enough income 

to make the house payment yet were over spending and taking advantage of 

the system."

Staff Perspective: Treasury encourages that program requirements not be burdensome on 

homeowners. Treasury also does not require homeowners to “demonstrate” 

their need beyond meeting program requirements. Necessary documentation 

and review will be developed as a part of the program guidelines.

Via Survey; 

Program Eligibility:

"The definition of method of assessing "reasonable expectations could give 

further clarity to the meaning of this phrase, such at the amount of assistance is 

effective, rather than raising expectations only to have the homeowner enticed 

but ultimately disappointed due to the value provided that does not address 

enough of the problems to make this solution anything more than too little 

money chasing solutions that will cost more for the homeowner to remain in 

place. Also, as I consider conditions "to be met" to prove eligibility I hope 

guidance is provided on how an applicant "proves" it."

Staff Perspective: Will be developed as a part of the program guidelines.

Via Survey; $60k 

Grant Amount:

"In reviewing the plan, it looks like eligible homeowners will be able to receive 

assistance with HOA dues and fees independently of a need related to mortgage 

forbearance or delinquency. I believe this is important because there are very few 

consumer protection tools available to homeowners as it related to HOAs. 

Additionally, some homeowners whose hardship prevents them from paying both 

their mortgage AND their HOA will prioritize paying their mortgage to avoid 

default and end up in significant arrears on the HOA, with fewer options to 

resolve things. The majority of homeowners seeking help will be those with 

mortgage issues or issues with both mortgage and HOA, but it is good to see that 

the homeowners who do need help with HOA only will be able to apply and 

received assistance if they otherwise qualify. Thank you!"

Staff Perspective: Comment received.
Proposed HAF Plan Comments – Through Noon on March 22, 2022

Page 3

Via Survey; $60k 

Grant Amount:

"Mortgage assistance up to $60,000 is a lot of money. Is it expected that most 

applicants will qualify for the maximum amount? If so, this funding will help less 

than 2,000 homeowners."

Staff Perspective: The PILOT program has brought us applicants in excess of $60,000 in needed 

relief, as well as those that do not need the full $60,000. We agree this is a finite 

resource which is why we are 1) funding counseling and civil legal aid; and 2) 

having applicants reviewed for all options available to them through their servicer 

and other programs, prior to funding being distributed.

Via Survey; $60k 

Grant Amount:

"Is the payment to a housing counselor part of the $60,000? Are there enough 

"civil legal aids" to provide guidance for no fee to meet the need? Will housing 

counselors be available is sufficient supply to work with all who would like to 

apply? I also have concern about not mention of "Mortgage Insurance Premiums" 

(MIPs). This is an area of great abuse since it should be reduced to zero is the 

equity/appraised value of the home, measured against debt has achieved by LTV 

80% LTV. This often never gets reviewed and corrected so that this expensive MIP 

monthly stops being charged."

Staff Perspective: Housing counseling is paid through administrative fees in excess of the program 

funding. Removal of Mortgage Insurance Premiums is not a direct component of 

the proposed program, but may be a part of the counseling process.

Via Survey; $60k 

Grant Amount:

"You have to provide more funds and help with closing costs. Income levels 

should also be increased to keep up with the high cost of housing. Also you need 

to consider allowing buyers to waive inspections so they can be completive in the 

market"

Staff Perspective: Comment received. 

Via Survey; $15k 

Grant Amount:

"Any funds allocated through the Treasury should go to a fully vetted candidate. 

To blindly allow a homeowner to apply for $15,000 financial assistance without 

the assistance of a housing counselor will bog down the system & could 

potentially exhaust funds before those in dire need, with proof, receive them."

Staff Perspective: All applicants will be required to go through an application process to determine 

eligibility and use of funding.

Via Survey; $15k 

Grant Amount:

"Is there a requirement among those who received $15K to continue reporting on 

the outcome of the assistance, or is that available on-line in some way to 

determine if the $15K continued to keep a homeowner from foreclosure, or 

forbearance, or future late payments?

Staff Perspective: Payments are made to a third-party to ensure they eliminate any default. There is 

no monitoring of the homeowner in the future.
Proposed HAF Plan Comments – Through Noon on March 22, 2022

Page 4

Via Survey; 

Eligible Uses:

"I appreciate the stated intention to outreach to underserved communities and 

believe that this is an important strategy to ensure the assistance is available to 

those most impacted by the pandemic."

Staff Perspective: Comment received. 

Via Survey; 

Eligible Uses:

"By allowing the funds to be used beyond mortgage payments, you are helping to 

insure that homeowners are not just staying in their homes, but that these homes 

stay safe and habitable. There are a variety of non-profit and government run 

low-interest home repair loan programs in Washington, and being able to use 

these funds to access these programs is a great idea."

Staff Perspective: We strongly support the home repair programs throughout Washington and will 

encourage their usage. 

Via Survey; 

Eligible Uses:

"Not understanding "down payment assistance loans provided by non-proit or gvt

entities" Is this for new home owners? Thought the intention of the program was 

for existing homeowners in trouble financially. The program, then, is "home 

owner expansion and access" not just remedy for financial strain? A little 

confusing I think."

Staff Perspective: These are allowed usage of the funds. They can be used to repay down payment 

assistance loans provided by non-profits and governmental agencies as a part of 

curing a default or negotiating lower interest rates or other retention options.

Via Survey; 

Eligible Uses not 

Implemented:

"I look forward to working with the Commission and any other partners on other 

programs to expand access to repair and modification assistance to Washington 

homeowners."

Staff Perspective: Comment received. 

Via Survey; 

Eligible Uses not 

Implemented:

"How can you have a homeowner assistance fund and not assist with being 

behind on your mortgage due to the pandemic."

Staff Perspective: The proposed program assists homeowners not current with their mortgage 

payments. 

Via Survey; 

Eligible Uses not 

Implemented:

"This seems appropriate, as these programs already exist elsewhere."

Staff Perspective: Comment received. 

Via Survey; 

Eligible Uses not 

Implemented:

"Agreed."

Staff Perspective: Comment received. 
Proposed HAF Plan Comments – Through Noon on March 22, 2022

Page 5

Via Survey; 

Eligible Uses not 

Implemented:

"No doubt home owners in default or close to default might have arrearages in 

these costs as well that are excluded. I would suggest that utilities should be 

included--without that, this becomes another program where it's not One-Stop 

efficiency, but requiring home owners to braid together various resources, using 

scarce time, energy and research to manage that puzzle of what from where, 

how, and when."

Staff Perspective: Assistance regarding payment of utilities is not a focus of the proposed plan.

Via Survey; Closing 

Comments:

"Thank you for your commitment to Washington homeowners and to your 

partners in the foreclosure prevention safety net. Together, we will get folks 

back on track! Looking forward to rolling up my sleeves with you when this 

excellent plan is approved by the U.S. Department of the Treasury."

Staff Perspective: Comment received.

Via Survey; Closing 

Comments:

"This seems like a great opportunity to help those impacted by COVID-19 stay in 

their homes. I wish there had been more information on the specific counseling 

that will be provided to insure homeowners can continue to make future 

mortgage payments/payments after grant funding is exhausted. It is important 

to help them on the path toward long-term success."

Staff Perspective: Default housing counseling requires providing assistance to the homeowner for 

future success.

Via Survey; Closing 

Comments:

"You should not make being affected by Covid a requirement. There is so much 

need for assistance nowadays that its ridiculous to add that restriction. There is 

some flawed thinking going on I think."

Staff Perspective: A COVID-19 impact is required by Treasury in the program.

Via Survey; Closing 

Comments:

"These funds must be allocated out only to those who have been most 

stringently vetted. All bank statements reviewed showing all deposits, spending 

habits, utility bills reviewed etc. We must take the time to make sure we helped 

those in dire need and not those not wanting to help themselves. We have 

elderly & Veterans struggling. We must peel back the layers and say NO to 

those who we can see dug a hole so someone else could bail them out. 

Shopping every day, nail salons, fast food, expensive coffee but not paying 

utilities each month on the bank statement doesn't mean you're worried about 

making ends meet."

Staff Perspective: Treasury encourages that program requirements not be burdensome on 

homeowners. Treasury also does not require homeowners to “demonstrate” 

their need beyond meeting program requirements. Necessary documentation 

and review will be developed as a part of the program guidelines.
Proposed HAF Plan Comments – Through Noon on March 22, 2022

Page 6

Via Survey; Closing 

Comments:

"Some of your clients fell into forbearance use some of that money to help pay 

the forbearance debt since their credit is already messed up"

Staff Perspective: Comment received. 

Via Survey; Closing 

Comments:

"It is interesting that $60,000 is provided in cash assistance for home owners, 

who also get a mortgage interest deduction on annual income for tax purposes. 

If we were to convert this to hypothetically thinking of the renter experience, 

that would be $5,000 per month in subsidy for one year. Or $2,500 per month 

in subsidy for 24 months. I suspect this would prevent significant numbers of 

evictions due to inadequate financial resources. Or $1,660 per month for 3 

years. Not relevant perhaps but interesting all the same."

Staff Perspective: Comment received. 

Via Survey; Closing 

Comments:

"Recommend very specific guidelines to determine that the financial need is 

attributable to Covid-related issues. Otherwise, loose interpretation will result 

in questionable claims."

Staff Perspective: Treasury has encouraged the use of attestations whenever possible. The Covidrelated impacts are well-defined.

Via Email: I am requesting information on the Homeowner Assistance Fund, which is funded 

through the US Department of Treasury. I have read the Department of Treasury 

guidance and I'm a little bit confused about the requirements. I am not in 

forbearance or foreclosure. The US Department of Treasury makes it clear that a 

person does not have to be either in foreclosure or forbearance in order to apply 

for funds. Rather, this is a federal program, in part, to provide federal assistance 

in order to prevent homeowners from either foreclosure or forbearance. I am 

asking for someone to explain to me why Washington State is apparently deciding 

to not adhere to federal guidelines. I am a homeowner trying to find any possible 

financial assistance to help defray expenses.

Staff Perspective: We are confident that the proposed plan meets Treasury’s and Congress’ intent 

for these funds and are consistent with Treasury’s guidelines. Treasury will 

ultimately approve the plan.

Via Email: HFC might expand its planned short-term outreach (pg 14) to include notice to 

city/county home repair programs. These programs are common to most 

city/county governments and target homeowners with low-incomes and 

physically distressed housing. HUD Region X staff can likely provide contact info 

with their grantees statewide. This outreach may increase foreclosure prevention 

for homeowners less likely to independently seek help. 

Staff Perspective: We strongly support the home repair programs throughout Washington and will 

encourage their usage. 
Proposed HAF Plan Comments – Through Noon on March 22, 2022

Page 7

Via Email: You should make payment optional and no enforcement mechanism, yes very 

similar to Governor Inslee’s Emergency pandemic order. I will be very excited to 

learn if the feds accept optional payment, no enforcement (OPNE).

Staff Perspective: Comment received. 

Via Public Comment 

Meeting:

What organizations will be handling the program?

Have we selected partners?

Will other organizations have an opportunity to be involved?

Staff Perspective: Using existing network; will likely have RFP process when additional funds are 

allocated by Treasury.

Via Public Comment 

Meeting:

Will we target aid by county? Some other method?

Wants to ensure the whole state is covered, but is concerned that the more 

agencies with their “hands in the pot pulling salaries”, the less is available for 

homeowners in need

Staff Perspective: Geographic distribution is a priority.

Via Public Comment 

Meeting:

Criteria for program eligibility? Will it be more stringent than self-attestation 

like in ERAP? Is concerned that this program will have similar problems to 

ERAP, that there is no programmatic mechanism to “prove you deserve it, 

actually need it”

Staff Perspective: Treasury encourages that program requirements not be burdensome on 

homeowners. Treasury also does not require homeowners to “demonstrate” 

their need beyond meeting program requirements. Necessary documentation 

and review will be developed as a part of the program guidelines.
Bill Rumpf

Chair

Steve Walker

Executive Director

1000 Second Avenue, Suite 2700, Seattle, WA 98104

Tel: 206-464-7139| 800-767-4663 | Fax: 206-587-5113 | wshfc.org

Below are the comments we have received AFTER 12:00 pm, Tuesday, March 22, 2022 through the 

closing of Public Comment at 5:00 pm on March 23, 2022. These comments are regarding the Proposed 

Homeowner Assistance Fund Plan scheduled for Public Hearing at your meeting on Thursday, March 24, 

2022. These materials supplement Tab Number 3 as well as the supplemental materials you received on 

March 23, 2022. 

ADDITIONAL COMMENTS:

Via Survey; General 

Comments:

"The plan looks good. More details are needed on process."

Staff Perspective: Comment received. 

Via Survey; 

Program Eligibility:

"Reasonable criteria aligned with the ARPA's criteria."

Staff Perspective: Comment received.

Via Survey; 

Program Eligibility:

"Looks Good."

Staff Perspective: Comment received.

Via Survey; $60k 

Grant Amount:

"Looks good."

Staff Perspective: Comment received.

Via Survey; $15k 

Grant Amount:

"Looks good."

Staff Perspective: Comment received.

Via Survey; 

Eligible Uses:

"Reasonable uses."

Staff Perspective: Comment received. 

Via Survey; 

Eligible Uses:

"To unwind a partial claim in a detailed and complicated process. ISN will be the 

service provider to make this happen. Not the mortgage servicer."

Staff Perspective: Comment received. 

PDF Page 2
Proposed HAF Plan Comments –Noon, March 22, 2022 through 5:00 pm March 23, 2022

Page 2

Via Survey; 

Eligible Uses not 

Implemented:

"Agreed, not the best use of limited funds."

Staff Perspective: Comment received. 

Via Survey; 

Eligible Uses not 

Implemented:

"Looks good."

Staff Perspective: Comment received. 

Via Survey; Closing 

Comments:

"While the commission has put together a reasonable plan, including criteria 

and eligibility, I believe that the commission could and should have allocated a 

portion of those eligible funds towards the ARPA's defined Socially 

Disadvantaged populations. The Commission determined that since 100% of the 

funding will be used towards those within the 100% income limit of AMI, it was 

within the commission's right to allocate less than 100% of funding to only 

income-limited households so that it could consider socially disadvantaged 

households. There is social science research that shows that regardless of the 

income threshold, socially disadvantaged groups face barriers to outright 

homeownership, and by dedicating 100% of the funding to the limit of income, 

the commission risks potentially exacerbating these existing disparities where 

income is not a direct limiting factor."

Staff Perspective: It was determined that a program that “targets” Socially Disadvantaged 

Individuals (SDI)—or other groups—was not permissible. Nor was it allowable 

to create set-asides for specific groups beyond Treasury’s specific guidelines for 

the program. Treasury’s guidelines state that SDI “must” be “prioritized” if the 

program AMI is in excess of 100% of AMI. At this time, the program 

contemplates a limit of 100% of AMI, so that requirement does not nor cannot 

apply. If the program is later adjusted to allow AMI beyond 100%, then SDI will

be “prioritized.”

Via Survey; Closing 

Comments:

"On the Technology Support Page. What is the difference between the State 

Assistance Call Center and the HAF Call Center? Will there be 

complications/confusion with different processing centers and data bases? Two 

call centers providing different services and reporting different data could 

confuse program oversight. Additionally, as a homeowner- who do I call? The 

program or third parties who will refer me back to the program (?) Referring to 

the list of services for the technology Program Service Provider is dense. 

Organizing these different technology providers and the state providers will 

require time and much consideration. (Then integrate servicers) If possible, as 

the tools are developed, convene servicers and educate on process. Its safe to 

say, at least half of the stakeholders will be out of State. How could services be 

combined with the partners already identified? It seems the program will be 

managing many stakeholders: Non profits 2 call centers Servicers Technology 

vendors Attorneys Existing State Programs (Mediation Program) Where can 

PDF Page 3
Proposed HAF Plan Comments –Noon, March 22, 2022 through 5:00 pm March 23, 2022

Page 3

some efficiencies or removing duplication of services be removed? If the above 

path is chosen, there will be several hundred folks that need to be organized 

and educated. Thank you for the opportunity to comment on your program."

Staff Perspective: The HAF Call Center is a support center for users of the application portal. This

could consist of homeowners, counselors, civil legal aid, or other advocates that 

have issues with the technology necessary to complete the application process. 

The HAF Call Center is NOT where homeowners go to seek assistance with their 

mortgage issues. The proposed program will focus its efforts on getting 

homeowners to contact the existing state-supported foreclosure hotline: 1-877-

894-4663 where they can receive assistance; including accessing potential HAF 

funding. It is our intention to make it as seamless and easy as possible for 

homeowners to receive assistance.

PDF Page 4
 1

Memo

To: Lisa DeBrock and Rich Zwicker, WA State Housing Finance Commission

From: Foreclosure Fairness Program Team, WA State Department of Commerce 

Date: March 29, 2022

Subject: Comments on the Homeowner Assistance Fund plan to be submitted to U.S. Department of Treasury

Thank you for allowing Commerce staff time to review and comment on your proposed HAF Plan. 

Below are the comments Commerce would like on record. We are happy to answer any questions you 

might have or provide more information. 

1. The main mortgage assistance program proposes a $60,000 limit. It is unclear from the plan 

how that number was derived, and whether there is data that suggest this level of funding will 

meet the needs of the arrearages homeowners face while still helping the greatest number of 

homeowners possible. Is there any background data or methodology that could be shared to 

provide insight into the limits established in the plan? Response: we used internal delinquency 

data for the Commission’s portfolio, along with other industry data, and feedback from our 

housing counseling network and civil legal aid, to determine the grant limit. 

2. The plan includes $15,000 direct grants via a streamlined process for those homeowners who 

choose not to work with a housing counselor. That process does not seem to include an indepth review of the homeowner’s financial situation. Additionally, the plan does not speak to 

what safeguards are in place to determine the viability of a grant to this group of homeowners. 

It would benefit homeowners, stakeholders, the real estate community, and public partners to 

have some insight into how these homeowners will qualify for the $15,000 grant. Response: All 

applicants will be thoroughly reviewed for eligibility per program and Treasury guidelines, but 

the $15k grants do not require—although they can work with—housing counselor assistance.

3. In combination with our first comment on how the $60,000 limit was derived, has the 

Commission considered any monitoring protocols or safeguards to prevent a sale of a home 

after an award has been made? If the $60,000 limit will potentially prevent the HAF from 

serving every homeowner in need, it would be beneficial to have some safeguards in place to 

prevent program funds from being used to exit homeownership with equity vs. stabilizing longterm homeownership. Response: The program does not require that a homeowner be 

HOMEOWNER ASSISTANCE FUND
 2

prohibited from moving or selling their home, because of the undue burden it could place on 

the homeowner by restricting their ability to move (new job, family, etc.). However, applicants 

will attest that it is their intention—at the time of application—to remain in their homes for one 

year.

4. Other commenters have raised the issue of visibility into the determination that socially 

disadvantaged individuals cannot be specifically prioritized with the 100% AMI cap. It would be 

helpful for stakeholders, and in particular those organizations and leaders serving 

communities of color, to have information on how this determination was made and some 

visibility into that analysis. Response: Treasury guidelines are clear that SDI “prioritization” 

should occur only on those that exceed the 100% AMI limit. On advice of counsel, it was 

determined that the program must be “open to all” and could not specifically target individual 

groups.

5. The plan contemplates options that exceed the limits provided by Treasury guidelines (e.g., 

civil legal aid and housing counseling in excess of 5% of HAF). Where the plan contemplates 

options that require Treasury’s approval, could the Commission provide insight into what the 

path is for implementing the HAF in the absence of such approvals? Response: If the full 

funding is not approved by Treasury, then the lower funding amount will be used to initially 

fund the program and alternative funding sources will be sought as the program progresses.

6. The plan contemplates “down payment assistance loans provided by nonprofits or 

government entities.” As others have commented, that phrasing appears to indicate that down 

payment assistance will be part of the HAF. It would be helpful to clarify if that is the intent, or 

if this is the payment of existing down payment assistance loans held by nonprofits or 

government entities. Response: This was an approved use of program funding and we did not 

want to decline the opportunity to avail the program of this option in case it could be 

appropriate in the future. And “down payment assistance loans” that are a part of a 

homeowners overall situation could be eligible for payment if necessary. However, a targeted 

program for down payment assistance loans is not being considered at this time. 

7. To the extent possible, although it may be limited, it would be helpful for stakeholders to have 

insight into how the current pilot program shaped specific decisions in the HAF plan.

Response: The PILOT Program exposed that those currently in foreclosure are subject to hardmoney lenders not required to provide post-COVID exit strategies and confirmed that the $60k 

limit was appropriate (and often even more is needed).