U.S. Department of the Treasury

Homeowner Assistance Fund (HAF): Closeout Resource

The following information is to be used as a resource by HAF recipients (“recipients”)1for 

closeout of their Homeowner Assistance Fund (HAF) awards. The period of performance for 

HAF awards (including Tribal allocation adjustment payments, as applicable) ends on September 

30, 2026.

• Section I of this document details closeout information and resources.

• Section II of this document provides additional post-closeout compliance reminders.

Recipients are advised to monitor the HAF Guidance page on Treasury’s website for additional 

compliance resources.

Section I: Closeout Information and Resources

General Closeout Overview

The purpose of award closeout is to ensure that:

• recipients have completed the HAF award objectives as outlined in their HAF plan.

• HAF Final Reports indicate that HAF award funds were expended on allowable costs.

• any balances of unobligated and unexpended funds remaining on the HAF award are 

returned to Treasury. 

• a proper accounting of any real or tangible personal property purchased with HAF award 

funds is submitted.

• recipients certify that the data submitted in the HAF Final Reports comply with the terms 

and conditions of the HAF Financial Assistance Agreement.

The period of performance (POP) for HAF awards ends on September 30, 2026 (end of the 

award term), which marks the last day that recipients may obligate HAF award funds for

administrative and program expenses, and such obligations must be paid in full within 120 

calendar days after September 30, 2026 to facilitate inclusion of those transactions in the Final 

Reports. 

For the purposes of this document, please note the following distinctions:

• recipients that have not initiated award closeout and the award POP has not expired will 

be referred to as having “open awards.”

1 HAF Guidance also refers to HAF recipients as “HAF Participants.” These terms may be used interchangeably. 
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• recipients that submitted the Final Reports to Treasury for closeout of their HAF award 

within 120 calendar days after September 30, 2026 are in “standard closeout.”

• recipients may choose to initiate the award closeout process before September 30, 2026

and those that do so are engaged in “early closeout.” 

• “closed awards” refer to recipients for which Treasury has completed its closeout 

process on their award and issued a Notification of Completion to the recipients. 

All recipients are required to submit their Final Reports to Treasury to close out their HAF 

award. The “Final Reports” consist of two reports, the HAF Annual Report and the HAF 

Quarterly Report, which includes a special section for tangible personal property.2 Treasury 

reserves the right to request additional documents to support the Final Reports. Failure to 

submit timely and accurate Final Reports may result in administrative closeout and affect 

future Federal funding to the HAF recipient.3 Treasury may also pursue other enforcement 

actions per 2 CFR 200.339. No later than 120 calendar days after September 30, 2026, recipients 

must complete the following closeout activities:

• reconcile financial expenditures associated with the HAF award.

• liquidate all HAF award obligations incurred by September 30, 2026. 

• determine whether any balances of unobligated and unexpended funds remain on the 

HAF award. 

• determine the status of all real and tangible personal property and unused supplies 

purchased with HAF award funds.

• prepare and submit the required Final Reports to Treasury.

Figure 1: General Closeout Process 

•

•

•

•

•

•

*Generally, the Notification of Completion will be issued within one year of the POP end date (September 30, 2026)

or, in the case of early closeout, one year from the date the recipient submitted the Final Reports to Treasury.

2 Please see page 7 for more details.

3

If the recipient fails to submit the Final Reports, Treasury may proceed with administrative closeout of the HAF 

award in accordance with 2 CFR 200.344(h) and the recipient will be deemed noncompliant with the HAF Award 

Terms. 

Treasury 

sends 

Notification of 

Completion*

No further award expenditures are permitted.

Recipient 

submits Final 

Reports

Recipient 

conducts award 

closeout 

activities 

See sections on 

“standard” or 

“early” closeout for 

details.

Treasury 

Closeout 

Review

Recipient 

returns 

unspent or 

disallowed 

funds to 

Treasury
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After the submission (or submission deadline) of a recipient’s Final Reports, Treasury will 

implement a Closeout Review of HAF awards (see page 9 for more details). Upon the 

completion of closeout actions and resolution of any outstanding matters regarding the HAF 

awards, Treasury will send a Notification of Completion.

“Early Closeout” Process 

Recipients that complete all award objectives, including administrative actions (which include 

any final operational activities), on their HAF award prior to September 30, 2026 may initiate

“early closeout” of their HAF awards.

4

Recipients initiate early closeout by submitting the Final Reports. Any final obligations must 

be liquidated (expenses charged/billed against the award must be completed) and operational 

activities associated with the award must be completed prior to submitting the Final Reports to 

Treasury. Once the recipient has submitted the Final Reports to Treasury, the recipient may not 

obligate or expend any remaining award funds for any purpose. Once the recipient submits the 

Final Reports, the recipient is also no longer required to submit regular HAF quarterly and 

annual reports. The recipient will remain subject to records retention and audit requirements (see 

page 13 for more details).

Treasury has established a review process to help support a successful early closeout (Figure 2):

1. Recipient determines that it will soon be ready to initiate early closeout, forecasting 

completion of award objectives and expenditures, including administrative actions like 

final operational activities.

2. Recipient may request to closeout its award early through Treasury’s Portal. 

3. Treasury will review the early closeout request and consult with the recipient, if 

needed. 

4. Treasury will notify and provide the recipient access to the Final Reports through 

Treasury’s Portal, if Treasury determines that the recipient may proceed with early 

closeout. 

4Per 2 CFR 200.340, the early closeout of a HAF award can be triggered by one of the following circumstances: (1) 

the recipient expended all its award funds and completed all the objectives of the HAF award, including 

administrative actions, prior to the end of the award POP; (2) termination of the HAF award by the recipient prior to 

the end date of the POP because it is no longer able to carry out the objectives of the award (see 2 CFR 

200.340(a)(3) or (4)); (3) termination of the HAF award by Treasury prior to the end date of the POP because the 

recipient failed to comply with the requirements of the Financial Assistance Agreement (termination for cause, see 2 

CFR 200.340(a)(1)); or (4) termination of the HAF award by Treasury prior to the end date of the POP because the 

award no longer effectuates the program goals or agency priorities (termination for convenience, see 2 CFR 

200.340(a)(2)).
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5. The recipient submits the Final Reports to Treasury to initiate the award closeout 

process. Note that the recipient must continue to submit all regular quarterly and annual 

reports until the Final Reports are submitted to Treasury.5

In general, Treasury will begin to review the Final Reports within 90 days. Treasury will 

work with the recipient to finalize the award closeout, generally within one year of the 

submission of the Final Reports.

Figure 2: “Early Closeout” Process

*Please refer to Figure 1: General Closeout Process for process steps following the start of Treasury’s Closeout 

Review process.

“Standard” Closeout Process and Timelines

The end of the award term marks the beginning of the “standard” closeout process for all

recipients of HAF awards that did not initiate early award closeout. Recipients will have 120 

calendar days after September 30, 2026 to submit their Final Reports to Treasury via Treasury’s 

Portal. Subrecipients must submit the final financial and performance reports, as applicable, to 

the recipients no later than within 90 calendar days after September 30, 2026 (Figure 3).

5 Treasury retains the right to reject the submission of a recipient’s Final Reports. In this case, the recipient must 

continue to submit regular quarterly and annual reports through the end of the award POP.

Recipient

•Forecasts 

completion of 

award 

objectives and 

expenditures, 

including 

administrative 

actions.

Recipient

•Requests 

early closeout 

through 

Treasury's 

Portal.

Treasury

•Reviews the 

early closeout 

request, which 

may include a 

consultation 

with the 

recipient.

Treasury

•Grants the 

recipient access 

to the Final 

Reports 

through 

Treasury's 

Portal.

Recipient

•Submits Final 

Reports to 

Treasury

Note: the recipient 

must continue to 

submit quarterly 

and annual reports 

until the 

Final Reports are 

submitted to the 

Treasury.

Program POP

Recipient may obligate and expend funds according to the various 

requirements of the HAF award; all obligations must be liquidated 

prior to submitting the Final Reports.

Treasury’s Early 

Closeout 

Review Begins*

No further award expenditures are 

permitted.
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Recipients must obligate award funds by September 30, 2026 to cover administrative costs 

for closeout activities carried out during the liquidation period (October 1, 2026 - January 28,

2027). Obligations incurred by September 30, 2026 for allowable administrative and program

expenses must be paid in full prior to the end of the liquidation period and those transactions 

must be included in the Final Reports, which must be submitted to Treasury by January 28, 

2027.

6

Figure 3: “Standard Closeout” Process and Timeline

*Please refer to Figure 1: General Closeout Process for process steps following the start of Treasury’s Closeout

Review process.

After September 30, 2026, recipients are prohibited from using HAF award funds for the 

following program activities:

• new obligations of funds to support administrative activities;

• assessment of applicant eligibility for HAF services and assistance;

• provision of counseling or legal services to homeowners;

• prospective assistance. Examples of prohibited prospective assistance expenditures

include but are not limited to:

6 Note that obligations incurred by subrecipients by September 30, 2026, must be paid in full within 90 calendar 

days after September 30, 2026 for allowable administrative and program expenses or an earlier date as agreed upon 

by subrecipient and recipient. 

Recipient may 

obligate and 

expend funds.

October 1, 2026

Start of the 

liquidation period 

following the end of 

the Period of 

Performance

December 29, 2026

Subrecipient's final 

financial and 

performance reports 

are due to recipient 

(monitored by the 

recipient)

January 28, 2027

Recipient's Final 

Reports are due to 

Treasury

Treasury’s

Closeout 

Review 

Begins*

Award POP

Recipient may expend funds obligated by 9/30/2026 for 

allowable administrative and program activities; all 

obligations must be liquidated prior to submitting the Final 

Reports to Treasury.

No further award expenditures are 

permitted.

Recipient 

submits 

Final 

Reports

Liquidation Period
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o mortgage payment assistance to prospectively cover mortgage expenses beyond 

September 30, 2026;

o home repair costs where the home repair activities occur after September 30, 

2026.

Allowable administrative and program activities using HAF award funds must be obligated by 

September 30, 2026 and may include:

• administrative expenses to support closeout activities (including administrative support 

services and other direct and indirect expenses that support administrative activities 

provided through staffing costs, subawards, contracts, preparation of Final Reports and 

documents, etc.).

• payment processing for:

o approved HAF applicants; this would include payment processing for mortgage 

reinstatement, utilities, or other allowable expenses incurred prior to September 

30, 2026. Note that payment processing is prohibited for prospective program

expenses (e.g. prospective mortgage, utility bills, housing counseling, etc.) that 

are incurred after September 30, 2026.

o housing counseling or other services that occurred prior to September 30, 2026.

• documentation, assessment, and retention activities. See page 8 for details on obligating 

and expending funds for this purpose. 

• data security measures and protection of personally identifiable information, which may 

include appropriate measures to ensure that the privacy of homeowners is protected and 

provide confidentiality protections for data collected about any homeowners who are 

survivors of intimate partner violence, sexual assault, or stalking.

• review and reconciliation of general ledger, accounting, reporting, bank reconciliation, 

program policies, procedures, and controls to prevent fraud and improper payments, 

which may involve follow-up with end-beneficiaries (e.g., homeowners, mortgage 

servicers, utility companies) to reconcile documentation, as needed.

• continued internal auditing of approved applications for potential duplication of benefits 

and associated remedial activities, as appropriate.

• single audits or program-specific audits required per 2 CFR 200 Subpart F, Audit 

Requirements, if applicable.
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Preparing to Submit Final Reports

Recipients must submit Final Reports with cumulative financial, tangible personal property, and 

performance information. For general reporting requirements and other reporting resources, 

please see HAF Reporting webpage.

The following considerations and questions can help support an accurate report and clear 

communications as recipients work through the closeout process: 

• Does the budget in Treasury’s Portal accurately reflect your actual HAF award budget?

Recipients may make adjustments to their budgets through Treasury’s Portal, but these

changes should be submitted to Treasury for approval prior to accessing their Final

Reports.

• Does the data align with HAF program guidance?

For instance:

o Does the total amount expended for planning, community engagement, needs

assessment, and administrative expenses fall within the limit of 15% of the total

HAF award amount as set forth in the HAF Guidance?7

o Does the total amount expended on housing counseling and legal services fall

within the limit of an aggregate amount up to 5% of the total HAF award amount

as set forth in the HAF Guidance?8

• Do the Final Reports accurately reflect the recipient’s aggregate financial and

programmatic data throughout the award POP?

Recipients should check:

o whether total expenditures and obligations align with the total (net) award.

o whether there are any unobligated balances by the end of the POP or unliquidated

obligations by the end of the closeout period; if yes, see page 10 for more

information about repaying of HAF award funds.

o the completeness and accuracy of the project data and participant demographics

(as applicable), as submitted in the Final Reports.

o to ensure that any tangible personal property, supplies, or other assets purchased

for the provision of allowed activities to support the housing stability of eligible

homeowners were installed prior to the expiration of the POP (in the case of

standard closeout) and prior to the recipient submitting the Final Reports (in the

case of early closeout). For example, propane tanks and fuel purchased to cover

utility costs or materials to support home repair projects must be delivered to and,

as applicable, installed for the homeowners prior to September 30, 2026 to be

considered an eligible expense for standard closeout.

7 See HAF Guidance for information on the limit for planning, community engagement, needs assessment, and 

administrative expenses (page 4).

8 See HAF Guidance for the limit on expenses for housing counseling and legal services pursuant to the HAF 

Guidance (page 4). 
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• Have you accounted for record retention requirements?

The HAF Financial Assistance Agreement stipulates that recipients must retain records 

pertaining to the HAF award for 5 years after all funds have been expended or returned to 

Treasury. 

o Any administrative funds utilized to support record retention requirements: 

• must be reasonable and consistent with the recipient’s policies and 

procedures regarding the standard for retaining such records and the 

amount of money the recipient would have paid for retaining its nonfederal records.

• must not exceed the limit for administrative costs which is 15% of the 

total HAF award amount.

• should not be the cost of maintaining a financial system for its Federal 

awards.

• must be obligated by September 30, 2026, end of the award POP and such 

record retention obligation must be paid in full during the closeout period 

(120 calendar days after September 30, 2026) and prior to the recipient’s 

submission of its Final Reports to Treasury to the extent that the record 

retention expense is within the 15% limit on administrative costs.

o Recipients must ensure that the method of record retention used for HAF award 

records is secure and it sufficiently protects the personally identifiable 

information and other sensitive information the recipients collected from 

homeowners and others to implement their HAF award. 

• Did you purchase equipment or supplies that will need to be reported? 

All HAF recipients must report on tangible personal property (equipment and supplies) 

acquired with HAF award funds during the award POP. Grantees are responsible for 

reporting on behalf of their subrecipients if their subrecipients used HAF award funds to 

acquire equipment or supplies, or both. 

Tangible personal property that needs to be reported in the Final Reports include: 

o Acquired equipment with an acquisition cost of $5,000 or more. 

o Residual inventory of unused supplies with a total aggregate fair market value 

greater than $5,000.

Per the Uniform Guidance, 2 CFR 200.1, tangible personal property includes equipment

and supplies. It does not include copyrights, patents or securities. A computing device is 

considered a supply if the acquisition cost is less than $5,000 per unit, regardless of the 

length of its useful life. 

Consistent with the Uniform Guidance, 2 CFR 200.313(e)(1), equipment acquired with 

HAF award funds with a current per unit fair market value of $5,000 or less at the end of 

the award period of performance may be retained, sold, or otherwise disposed of by HAF 

recipients with no further responsibility to Treasury. Supplies acquired with HAF award 
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funds with the total aggregate value of $5,000 or less at the end of the award POP may 

also be retained by HAF recipients with no further responsibility to Treasury. 

Additionally, Treasury permits recipients with equipment with a per unit fair market 

value of more than $5000 or unused supplies that have a total aggregate value of more 

than $5,000 to be retained by the recipient if it is needed for another federal award or for 

activities for non-federally funded programs or projects for the government entities which 

have similar objectives as the HAF program. 

Closeout Review of HAF Awards

After the submission (or submission deadline) of a recipient’s Final Reports, Treasury will 

implement a Closeout Review of HAF awards, which may include: 

• requesting verification of award closeout information from recipients,

• engaging recipients to resolve any issues found in their Final Reports; if a report requires 

revision, Treasury may send instructions to revise and resubmit the Final Reports or an 

Information Document Request (IDR) for the recipient to provide further clarity. 

• notification of disallowed costs, as applicable. 

• sending repayment instructions to recipients.

• initiating or proceeding with applicable remediation actions.

For each of these activities, Treasury will communicate specific instructions and deadlines to 

recipients. Treasury may engage in further compliance activities, closeout review, and 

communication with recipients, as needed and in alignment with applicable provisions of the 

Uniform Guidance (2 CFR Part 200), Treasury’s guidance, and the terms and conditions of the 

HAF Financial Assistance Agreement. If a recipient does not resolve outstanding issues, 

Treasury will provide a formal opportunity to remedy the noncompliance prior to the recipient 

being found noncompliant with the requirements set forth in the HAF Financial Assistance 

Agreement.

Upon the completion of closeout actions and resolution of any outstanding matters regarding the 

HAF awards, Treasury will send a Notification of Completion, informing each recipient that its 

award has been closed out and no further action is required other than its compliance with certain 

terms and conditions of the HAF award that extend beyond the closeout period.9

9 Examples of the terms and conditions of the HAF Financial Assistance Agreement that extend beyond the closeout 

period include record retention requirements, compliance-monitoring, and, if applicable, resolution of audit findings 

after award closeout.
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Repayment of HAF Award Funds

Following receipt and review of the recipient’s Final Reports, the recipient will enter into

“financial closeout” where Treasury reviews unliquidated obligations and unexpended award 

funds to determine any adjustments following the submission of the Final Reports and/or 

repayment amounts. 

If a recipient owes money to Treasury due to, for instance, excess funds, unobligated balances, 

improper use of funds, or other noncompliance issues under the HAF award, Treasury will send 

repayment instructions and deadlines to make payments, as appropriate (also referred to as a 

“pre-debt notice”), and if repayment is not made timely Treasury may seek other legally 

available remedies. Recipients will have 30 calendar days to repay funds to avoid debt collection. 

Once the recipient enters into debt collection, Treasury will issue a demand letter that outlines 

escalating penalties for non-payment per 31 U.S.C. 3717 (see Figure 4).

Figure 4: Repayment Process

Recipient submits 

Final Reports.

Treasury review of Final 

Reports; IDRs requested as 

needed to determine 

repayment amounts during 

Financial Closeout.

Treasury sends repayment 

instructions with return 

deadline (pre-debt notice).

Recipient returns funds in full 

within 30 calendar days of predebt notice to avoid debt 

collection.

DEBT COLLECTION

If outstanding amount remains, 

Treasury initiates debt collection 

and issues a demand letter.

AFTER 30 DAYS OF 

NONPAYMENT, 

Treasury will begin assessing 

and escalating penalties and 

interest on delinquent debts.
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In general, the conclusion of financial closeout is often the last step in Treasury’s closeout 

process and may be followed by Treasury sending the recipient a Notification of Completion

(see Figure 1). Please note that after the Notification of Completion, Treasury retains the right to 

engage in a post-closeout adjustment to disallow costs and recover funds on the basis of a later 

audit or other review pursuant to 2 CFR 200.345. 

If Treasury determines that a recipient is not in compliance with repayment instructions and/or 

have other outstanding issues, Treasury may also put a “financial hold” on the recipient’s 

HAF award, which may result in withholding of payments remaining on its other awards

under Treasury programs or take other enforcement actions.

10

Specific Repayment Situations

Earned Interest

Please also note that HAF awards are subject to the requirement to remit any annually earned 

interest on the HAF award above $500 to the Department of Health and Human Services’ 

Payment Management System pursuant to 2 CFR 200.305(b)(9)(ii). Annually earned interest 

refers to any interest earned by the grantee on the HAF award amount during the award period of 

performance, for instance, interest earned while HAF award funds were held in a deposit account 

at a bank.

If the annual earned interest is less than $500, the recipient may retain and use the funds for 

administrative expenses. These funds may be used for administrative purposes until the recipient 

submits the Final Reports. Once a recipient submits the Final Reports, any earned interest less 

than $500 must be returned to Treasury along with any unexpended HAF award funds.

Figure 5: Repayment Requirements for Earned Interest

Type of Funds Open Awards Upon Submitting Final Reports 

Earned interest > $500 

per year

Annually remit to DHHS PMS 

System

Remit to DHHS PMS System*

Earned interest < $500 

per year

May be retained for

administrative expenses

Must repay funds not expended as

administrative costs to Treasury along 

with unexpended HAF award funds

*Please note that any interest earned on unobligated HAF award funds remaining with the recipient after 

submission of its Final Reports must be returned to Treasury.

10 Per 2 CFR 200.339(a).
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Repayment of recovered or returned HAF Award Funds

Recipients receive recovered or returned award funds for several reasons. A recipient may 

recover program income (e.g., homeowner loan repayments) or improper payments. HAF 

recipients may also receive returned homeowner financial assistance from mortgage servicers, 

utility companies, home repair contractors, or other end beneficiaries for a variety of reasons. 

For most recovered or returned funds, recipients with open awards may redeploy any of these 

funds for HAF program purposes. Once a recipient enters the closeout process, recipients must 

repay funds to Treasury, with an exception specific to recovered program income. Recipients 

are not required to return program income to Treasury that they received after September 30, 

2026.11

Following the Notice of Completion, recipients should use the previously provided repayment 

instructions for any further repayments to Treasury, unless otherwise instructed.

Figure 6: Repayment Requirements for Returned or Recovered Funds

Prior to September 30, 2026 After September 30, 

2026

Type of Funds Open Awards Awards in “Early 

Closeout”

All Awards

Returned funds 

(e.g. homeowner 

financial assistance 

returned to recipient by 

servicer, utility company, 

home repair contractor, 

or other end 

beneficiaries)

May redeploy funds 

for eligible HAF 

purposes

Must repay funds to 

Treasury

Must repay funds to 

Treasury

Recovered 

Program Income

(e.g. homeowner loan 

repayments (principal 

and interest))

May redeploy funds 

for eligible HAF 

purposes

Must repay funds to 

Treasury

Not required to return 

funds to Treasury

Other recovered funds 

(e.g., recipient recovers 

improper payments, etc.)

May redeploy funds 

for eligible HAF 

purposes

Must repay funds to 

Treasury

Must repay funds to 

Treasury

11 Recipients that initiate early closeout must return recovered program income to Treasury between the period that 

they submit their Final Reports, initiating “early closeout,” and the end of the POP on September 30, 2026. After 

September 30, 2026, all recipients of HAF awards are not required to return recovered program income to Treasury.
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Section II. Post-Closeout Compliance Reminders

Following the submission of the Final Reports and the Notification of Completion, Treasury may 

continue to engage in further compliance activities, closeout-review, and communication with 

recipients, as needed and in alignment with applicable provisions of the Uniform Guidance (2 

CFR Part 200), Treasury’s guidance, and the terms and conditions of the HAF Financial 

Assistance Agreement. The following is a non-exhaustive list of post-closeout recipient 

responsibilities. 

Records Retention & Documentation

Per the HAF Financial Assistance Agreement, financial records, supporting documents, 

statistical records, and all other non-Federal entity records pertinent to the HAF award must be 

retained for a period of five years after all funds have been expended or returned to 

Treasury.12 If an audit, litigation, or other action involving the HAF records starts before the end 

of the appropriate retention period of five years, the records should be maintained until the end 

of the appropriate retention period or until the audit, litigation, or other action is completed, 

whichever is later.

Documentation of Compliance with Federal Civil Rights Statutes and Regulations:

Recipients are required to comply with federal civil rights statutes and regulations, including 

Title VI of the Civil Rights Act of 1964, Section 504 of the Rehabilitation Act of 1973, the Age 

Discrimination Act of 1975, and the Fair Housing Act (Title VIII of the Civil Rights Act of 

1968) as outlined in the HAF Financial Assistance Agreement executed by the recipients in 

connection with their HAF awards. Note: Treasury does not impose nondiscrimination 

requirements on Tribal governments beyond what would otherwise apply under federal law.

Information about the recipients’ civil rights obligations can be found in Treasury’s Civil Rights 

Toolkit. Information about LEP language requirements is found in Treasury’s Guidance to 

Federal Financial Assistance Recipients Regarding Title VI Prohibition Against National Origin 

Discrimination Affecting Limited English Proficient Persons. 

Audit Requirements

Thoughtful and thorough work related to award closeout can help support an accurate and 

effective audit. Audit activities may fall outside of the timelines associated with closeout 

activities. However, recipients with open awards may use HAF award funds towards single audit 

or program-specific audit costs, as applicable and within the administrative costs limit, for 

annual single or program-specific audits, as applicable, until fiscal year 2026 and in accordance 

with 2 CFR 200.425 and 2 CFR Part 200, Subpart F – Audit Requirements, as long as the costs 

are obligated before the end of the award POP and expended within 120 calendar days (or 90 

calendar days in the case of subrecipients) after September 30, 2026 per 2 CFR 200.344(a).

12 Please note that 2 CFR 200.334 provides that pass-through entities that receive federal awards must not impose 

any other record retention requirements on non-Federal entities, except those outlined in 2 CFR 200.334(a)-(f).
HAF Program Closeout Resource

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Please note that, in the case of a recipient engaging in early closeout, funds may not be 

expended to support audit activities after the recipient submits the Final Reports. 

Detailed information regarding single audits and program-specific audits can be found in 2 CFR 

Part 200, Subpart F, Audit Requirements. Here is some basic information regarding auditee 

responsibilities (2 CFR 200.508) to help recipients plan:

• Recipients that expend $750K or more in federal awards during their fiscal year are 

required to undergo either a single audit or program-specific audit for that fiscal year.

• Recipients are responsible for procuring or otherwise arranging for audits and ensuring 

the auditor has the necessary experience to perform this type of audit in accordance with 

2 CFR 200.509. 

o Information with instructions for how auditors must perform these audits can be 

found at 2 CFR 200.514-200.520 and in the HAF 2023 Compliance Supplement 

published by the Office of Management and Budget. 

o Recipients are advised to continue to check the HAF Guidance page on 

Treasury’s website for additional compliance resources, e.g., Compliance 

Supplements.

• Recipients must prepare their financial statements and other materials required by their 

auditors to perform their audits and provide the auditors with all necessary 

documentation (e.g., records).

• Recipients are expected to take prompt corrective action following any audit findings.

• Recipients must submit and certify their single audit reports to Federal Audit 

Clearinghouse “within the earlier of 30 calendar days after receipt of an auditor’s 

report(s), or nine months after the end of the audit period” per 2 CFR 200.512(a)(1). The 

audit period is a recipient’s fiscal year.

• Recipients with audit findings must work with Treasury, as appropriate, to resolve those 

findings.
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APPENDIX A: Definitions

Administrative activities generally include activities to support closing out the award in 

accordance with 2 CFR 200.344, including, but not limited, to administrative support services 

and other direct and indirect expenses that support administrative activities provided through 

staffing costs, subawards, contracts, preparation of Final Reports and documents, etc.

Administrative closeout occurs if the Final Report has not been submitted and Treasury initiates 

the closeout process on behalf of the participant, per 2 CFR 200.344 (h)-(i). 

Closeout refers to the process by which the federal awarding agency or pass-through entity 

determines that the participant (or subrecipient) has completed all applicable administrative 

actions and required work of the federal award have been completed. And therefore, the federal 

awarding agency or pass-through entity takes actions as described in 2 CFR 200.344.

Financial Closeout refers to the review of unliquidated obligations and unexpended award funds

by the end of the award term POP and closeout period. Financial closeout determines whether 

that amount will be repaid to Treasury and includes recoupment of any disallowed or ineligible 

costs.

Participant/recipients means the eligible entities, states, the District of Columbia, U.S. 

territories, Indian Tribes, Tribally Designated Housing Entities, and the Department of Hawaiian 

Home Lands that received a HAF award under the Homeowner Assistance Fund program 

pursuant to section 3206 of the American Rescue Plan Act, 2021. In the case of this document, 

"recipient" and "participant" may be used interchangeably. These terms do not include 

subrecipients (e.g. vendor, nonprofit partner, etc.) or beneficiaries of the award (e.g. 

homeowners, mortgage servicers, utility companies, etc.).

Period of performance means the total estimated time during which the recipient and 

subrecipient must perform and complete the work authorized under the Federal award; it is the 

interval between the start of an initial federal award and the planned end date.

Post-closeout adjustment describes activities that occur after a federal awarding agency closes 

out an award pursuant to 2 CFR 200.345. These activities include: (1) The right of the federal 

awarding agency or pass-through entity to disallow costs and recover funds on the basis of a later 

audit or other review; (2) The requirement for the recipient to return any funds due as a result of 

later refunds, corrections, or other transactions including final indirect cost rate adjustments; (3) 

The ability of the federal awarding agency to make financial adjustments to a previously closed 

award such as resolving indirect cost payments and making final payments; (4) Audit 

requirements; (5) Property management and disposition requirements; and (6) Record retention 

requirements. 

Remediation actions refer to activities pursued to correct a recipient’s noncompliance with 

statutes, regulations, or the terms and conditions of their award agreement.
HAF Program Closeout Resource

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Subrecipient means an entity that receives a subaward from a pass-through entity (e.g. a HAF 

recipient) to carry out part of a federal award; but does not include an individual that is a 

beneficiary (e.g. homeowners, mortgage servicers, utility companies, etc.) of such award.

Unexpended obligations means the amount of funds that have been obligated by the recipient 

under a federal award but not paid; may also be referred to as unliquidated obligations.

Unobligated balance means the amount of funds under a federal award that the recipient has not 

obligated.