1. You have indicated revised budget amounts in your feedback response, which do not 

appear to have been entered in the HAF portal budget. We need these figures to be 

corrected in the portal itself. We have reopened your plan for you to do so.

This has been corrected in the Portal.

2. On p. 4 of the feedback response (attached), you note that “Our proposed program 

structure first asks if a homeowner has accepted a loss mitigation option from their 

servicer. If they have, they are not eligible for our program.” Could you clarify how this 

eligibility requirement will work, specifically addressing how the requirement will be 

conveyed to homeowners that may be in the process of considering loss mitigation and 

whether homeowners who accept a loss mitigation option but later have difficulty 

making their mortgage payments will be eligible under any circumstances.

Our pre-screening and application process differentiates homeowners considering loss 

mitigation from homeowners who have accepted loss mitigation. All borrowers 

considering loss mitigation continue to be eligible for HAF and will be further screened 

based on whether they can afford their monthly payment or if they are behind and 

cannot afford the regular monthly payment. In the latter case, they will be evaluated for 

the HAF loan modification track.

We are modifying our original response and have adjusted our HAF program policy for 

homeowners who have already accepted loss mitigation and once again find themselves 

delinquent on their mortgage payments due to ongoing COVID related financial issues. 

In these instances, the homeowner will be evaluated for HAF. We acknowledge, and 

want to support, homeowners who may have accepted loss mitigation but later have 

difficulty making mortgage payments and through HAF can be supported in order to 

continue to preserve homeownership, even if for a short period of time while they 

resolve their financial situation or prepare to sell their home. 

As a result of modifying our policy in response to homeowners who have accepted loss 

mitigation and later have difficulty making their mortgage payments, we are adjusting 

our response to the Treasury question outlined in bold below. Our modified response is 

outlined in redline below the Treasury question.

• the role housing counseling or legal services providers will play in supporting

homeowners’ efforts at engaging in loss mitigation.

As a result of the early and ongoing referrals we have been making to housing 

counseling, by the time the HomeHelpMN program launches, many homeowners will 

have been referred to housing counseling to support loss mitigation efforts. For those 

homeowners who have not directly engaged with their loan servicer or a housing 

counselor around loss mitigation, we expect to make referrals to housing counseling in 
cases where additional support is needed to determine the household budget and 

whether the ongoing mortgage payment is affordable or not. All homeowners will be 

assessed based on answers to key triage answer a questions around whether they can 

afford to make ongoing mortgage payments (sustainability) to assist with housing 

counselor referral. This information will not be used for HAF eligibility determinations.

prior to using HAF funds to reinstate the borrower, or in cases where a borrower may be 

eligible for a loan modification.

As a result of the policy recommendation to permit borrowers to access HAF provided 

the household has a source of income, demand for reinstatement will increase. The 

total direct financial assistance program budget for HomeHelpMN is $108,613,356. We 

recommend increasing the budget allocation for reinstatement by just under $22 million 

and decreasing the budget for loan modifications (principal write down reduction and 

interest rate reduction) by that amount. The recommended budget changes are 

outlined in red (decrease) and blue (increase) below.

TOTAL PGM BUDGET AVAIL 108,614,356

Original Budget

% total 

budget Proposed Budget

% total 

budget

Mortgage Reinstatement 42,175,000 39% 60,452,129 56%

Principal Write Down 36,000,000 33% 19,550,584 18%

Interest Rate Reduction 4,000,000 4% 2,172,287 2%

Property Tax Delinquency 11,050,000 10% 11,050,000 10%

Homeowner's Insurance 11,700,000 11% 11,700,000 11%

HOA Fees/Liens 3,040,000 3% 3,040,000 3%

Downpayment Assist. Loans 649,356 1% 649,356 1%

108,614,356 100% 108,614,356 100%

3. On p. 7, you indicate that the three best metrics would reflect your primary goals, and listed 

those goals. If possible, could you provide specific metrics that will measure your 

performance towards these three goals?

• Share of assisted households with income at or below 80% AMI: 75%

• Share of assisted households who are SDI: 45%

• Share of HAF funding expended/paid by 12/31/2024: 100%