HAFP-0076-Florida
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Completeness
The participant’s response(s) to the following questions was/were either incomplete or
unresponsive:
Q: Plan indicates that zero funds were obligated from the initial 10% payment but notes
that funds were used for “salaries and benefits of the staff designing the program,
vendor support of plan development, and vendor development of IT systems”. Please
update the portal to reflect any funds obligated for these expenses.
A: As of June 30, 2021, the Florida Department of Economic Opportunity (DEO) has
entered into agreements with vendors to support the development of the Homeowner
Assistance Fund (HAF) Plan and the Information Technology (IT) system for a total
encumbrance of $1,837,920.
Homeowner Needs and Community Engagement
Data
Q: Please explain how the program expects to serve targeted populations without more
specific underlying data.
A: In order to serve targeted populations, DEO will use multi-faceted marketing methods,
including paid digital, social media platforms, email, text messaging, direct community
outreach using targeted community events, door-to-door canvassing, high traffic site
engagement, and strategic collaboration with community-based organizations.
Additionally, DEO has held numerous outreach calls with mortgage servicers, utility
providers, and homeowner and flood insurance providers to discuss their ability to help
identify and market the HAF program to customers who reside in qualified census
tracts.
For research purposes, DEO met with more than 20 organizations that specialize in the
various programs proposed under Florida’s HAF Plan. These meetings assisted DEO
with developing the Plan and gaining a better understanding of how to reach and serve
the targeted populations throughout the life of the program. Outreach and collaboration
were conducted with states, organizations, and companies that included:
• Florida Housing Finance Corporation
• US Bank
• Wells Fargo
• Citizens Property Insurance Corporation
• Duke Energy
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• Florida Power and Light / Gulf Electric
• Tampa Electric Company
• Florida Electrical Cooperative Association
• Legal Aid of Broward
• Florida Association of Court Clerks and Comptrollers
• National Council of State Housing Agencies
• National Housing Policy Council
• Commonwealth of Massachusetts
• State of Georgia
• State of Texas
• State of Maryland
• State of Michigan
• Florida DEO Bureau of Workforce Statistics and Economic Research
• Community Action Agencies (Florida Association for Community Action)
• Florida Housing Counselor Network
Q: Please explain how the plan targeting and outreach reflect the data referenced in your
plan.
A: DEO has selected a vendor with experience conducting education and data-driven
outreach campaigns in historically marginalized communities to implement the state of
Florida’s HAF Plan. The vendor will:
• Inform homeowners within targeted communities of the HAF program’s available
resources.
• Provide direct case file support so Florida’s distressed homeowners understand
how to navigate around any barriers that may prevent them access to HAF
programs, whether technology, social, language, and/or economic barriers, as
specified by Florida’s HAF Plan.
• Inform and assist individuals within targeted communities on the process to apply
for available relief funding.
• Establish intake and call centers that support DEO’s efforts to provide HAF
resources and reduce homeowner financial hardships.
Additionally, the vendor will conduct direct outreach and engage with communities
throughout the state focusing on awareness, education, and access activities that
provide a comprehensive program to drive eligible homeowners to apply and be
approved for financial assistance.
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Community Engagement and Public Participation
Q: Your plan indicates that only four organizations involved in your public input process.
Please explain how the program is confident in its ability to reach targeted populations
without engaging such organizations in planning and implementation.
A: DEO met with more than 20 organizations that specialize in the various programs
proposed under Florida’s HAF Plan. These meetings assisted DEO with developing
the Plan and gaining a better understanding of how to reach and serve the targeted
populations throughout the life of the program. DEO will utilize an approach that
consists of the following three elements: Awareness, Access, and Education.
Awareness activities will be designed to inform individuals within underserved
communities of available HAF resources, including in-person support. Access
activities will be centered on the strategic placement of temporary and permanent
intake centers, which will offer convenient and accessible alternatives. Education
activities will include strategic marketing campaigns, which will include content
messaging, media productions, and homeowner engagement. Outreach and
collaboration was conducted with states, organizations, and companies that included:
• Florida Housing Finance Corporation
• US Bank
• Wells Fargo
• Citizens Property Insurance Corporation
• Duke Energy
• Florida Power and Light / Gulf Electric
• Tampa Electric Company
• Florida Electrical Cooperative Association
• Legal Aid of Broward
• Florida Association of Court Clerks and Comptrollers
• National Council of State Housing Agencies
• National Housing Policy Council
• Commonwealth of Massachusetts
• State of Georgia
• State of Texas
• State of Maryland
• State of Michigan
• Florida DEO Bureau of Workforce Statistics and Economic Research
• Community Action Agencies (Florida Association for Community Action)
• Florida Housing Counselor Network
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Q: Your plan notes public input and community engagement in the plan development
process. Please explain how community engagement informed your plan’s
programmatic and outreach design.
A: As part of the development process for the state of Florida’s HAF Plan, DEO posted
a HAF Plan Overview of the state’s Plan to its website for public comment and
community engagement. In addition to the organizations that provided feedback, DEO
received thousands of responses from Florida homeowners who provided further input
regarding the state’s HAF Plan. DEO addressed this feedback throughout the Plan
submitted to the U.S. Treasury. Public comments included requests to expedite the
availability of the program to Floridians, to avoid excessive documentation and
qualification requirements, to establish an efficient and flexible process for submitting
applications, and to assist Florida homeowners in need to maintain future housing
stability. DEO staff have responded to more than 11,000 emails and phone calls and
has updated DEO’s HAF webpage to keep the public updated on program
developments. These public comments and community engagement confirmed the
State of Florida’s development of the HAF Plan, which is reflective of community and
constituent needs.
Q: Please provide an update indicating any public comments you have received since you
submitted your HAF Plan, from which organization you received any such comment,
and whether you have responded to the comments.
A: DEO has received and responded to 765 emails since the State of Florida’s HAF Plan
was submitted. Additionally, DEO hosted a webinar with more than 150 attendees to
inform the public on its plans for Florida’s HAF allocation. DEO continues to have
ongoing conversations with stakeholders.
Ongoing Assessment of Homeowner Need
• No questions.
Program Design
Q: Please explain how the sources of data listed in the section on Homeowner Needs
informed the Program Design Elements included in your plan.
A: DEO engaged professional service firms with experience in banking, economic
valuation, mortgage servicing, and data analytics to research and report on
homeowner needs across the state. The research found that approximately 57% or
more than 2.8 million households have a mortgage. Caucasian households are more
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likely than households of color to own their homes unencumbered from debt; 49%
versus 30%, respectively.
According to recent publications from Black Knight, Inc., a mortgage data provider,
and the Mortgage Bankers Association, it is estimated that, on average, homeowners
in forbearance have been in forbearance for 12 months. In order for the HAF Plan to
assist the mortgagee with reinstatement and assist with future expenses of
homeownership, the HAF Plan will include prospective financial support.
Q: Will there be a method in your HAF program, early in the process of engaging with a
household, to evaluate immediate threats to the housing stability of applicants, which
may need to be addressed under an expedited or prioritized timeline (e.g. HOA liens,
tax delinquencies, utility shut off)?
A.: The HAF program vendor selected has prior experience in managing federal programs
that required similar prioritization with intake, community outreach, and case
management. Florida’s HAF program operating manual will instruct case managers to
expedite applications for payments necessary to prevent imminent displacement.
Prioritization will take place based on the type of housing stability hardship, including
utility, property tax, homeowner and flood insurance, homeowner association fees and
liens, and broadband assistance.
Q: Please confirm your exclusion of reverse mortgages and contracts for deed or land
contracts and explain what steps you have taken to assess the needs of homeowners
with reverse mortgages and contracts for deed or land contracts. Please summarize
any community feedback or data on which you have based this decision. If these
borrowers can receive assistance under any program design element, please explain
and update your plan to reflect that they are not excluded from your program.
A: Homeowners with reverse mortgages, contracts for deed, and land contracts, who
otherwise qualify for financial assistance under the HAF program, may be eligible for
all other programs, including utility, property tax, homeowner and flood insurance,
homeowner association fees and liens, and broadband assistance.
Florida plans to focus on preserving homeownership and creating housing stability
by preventing foreclosure and displacement through the HAF Program. Reverse
mortgages allow senior citizens to access their home equity and defer loan payments
until they sell their home, move out of the home, or pass away. Because there are
no required mortgage payments on a reverse mortgage, financial assistance used
to reduce the balance or satisfy reverse mortgages would not, in most cases,
preserve homeownership or create housing stability. Moreover, in many cases, the
primary beneficiary of financial assistance used to reduce the balance or satisfy a
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reverse mortgage will be the homeowner’s heirs, who may not otherwise qualify f or
financial assistance under the HAF program.
Based on the data regarding Florida’s home ownership landscape and community
feedback, DEO’s research indicates contracts for deed and land contracts are
exceedingly rare in Florida. In addition, we are concerned with the increased risk of
fraud if Florida provided such financial assistance, particularly if the loans are private
and informal.
Q: Please describe how your program will utilize housing counselors or legal services to
assist homeowners in evaluating loss mitigation options available for their mortgage.
Your description should include:
o whether your program will connect homeowners with housing counseling or
legal services early in the process.
o the role housing counseling or legal services providers will play in
supporting homeowners’ efforts at engaging in loss mitigation.
A: To enhance program coordination, outreach to eligible homeowners, and efficient use
of funds, Florida proposes allocating program funds for housing counseling and
education services with a focus on loss mitigation and long-term housing stability. The
proposed counseling and education services program will support homeowners with
incomes that are less than or equal to 150% of the Area Median Income (AMI) or 100
% of the median income in the United States, whichever is greater, who are
experiencing financial hardships related to the COVID-19 pandemic. The proposed
housing counseling and education services program will provide support in an
accessible and effective manner and will be offered at the outset of case management.
Q: How will your program leverage resources available through a loss mitigation process
to benefit eligible homeowners and how will your program avoid using HAF funds in
ways that duplicate relief that available loss mitigation options might provide?
A: Based on data and other information that the state of Florida received from the Housing
Policy Council and loan servicers, DEO is confident that the mortgage loss mitigation
process will be substantially complete before Florida’s HAF program is approved and
is launched. Nevertheless, in cases in which loss mitigation is in process, the state of
Florida will only approve prospective mortgage assistance. We will also review
information as part of the case management process to prevent the duplication of
benefits with respect to mortgage payments and other programs and will require
homeowner attestations confirming the same.
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Q: Please explain what steps, if any, your program will take to assist the homeowner in
determining whether a HAF-resolution will result in a sustainable monthly payment.
A: The State of Florida plans to provide homeowners with financial assistance up to 18
months of future mortgage, property tax, homeowner and flood insurance, homeowner
association fees, and broadband and utilities payments, which will enable homeowners
to build or maintain financial stability and mitigate future financial hardships. Through
available housing counseling and education, the State of Florida will ensure that
participating homeowners who need assistance are able to take full advantage of these
programs and obtain guidance, counseling, and other information necessary to help
homeowners sustain the long-term costs of homeownership.
Q: Are you anticipating increased winter home energy costs and their potential impact on
the homeowners that HAF will serve?
A: The data from Florida does not indicate that there are significant increased winter home
energy costs.
Q: Please confirm whether your program will provide payment assistance for
homeowner’s association fees or liens, condominium association fees, etc. If not, please
explain your rationale for not providing such assistance.
A: Florida’s HAF program will provide payment assistance for homeowner’s association
fees and liens, as well as condominium association fees.
Q: Your plan indicates you will provide homeowners with assistance towards future
payments (up to 18 months) of property taxes, homeowners insurance, and utilities.
Please explain your rationale for providing such assistance, including what data from
your needs assessment specifically informed your determination.
A: According to recent publications from Black Knight, Inc., a mortgage data provider,
and the Mortgage Bankers Association, it is estimated that, on average, homeowners
in forbearance have been in forbearance for 12 months. Data indicates the vast
majority of loans that are in forbearance, or not current throughout the COVID-19
pandemic, have or will be modified and brought current by the lenders and servicers
by the end of 2021. Allowing eligible homeowners to receive extended financial
assistance for up to 18 months of eligible expenses will enable the homeowners to
build or maintain financial stability to mitigate future financial hardships.
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Eligibility
Q: Please provide the rationale for establishing the following additional eligibility
requirements specified in your plan, including how you determined these requirements
will not create unnecessary barriers to participation by eligible homeowners:
• Homeowners who have previously filed for bankruptcy, but who are no
longer in bankruptcy, must provide proof of court ordered discharge or
dismissal.
A: Subject to guidance by the HAF program’s legal counsel, homeowners pending
bankruptcy proceedings may qualify for the HAF program as long as payments do
not become part of the bankruptcy estate. Accordingly, Florida will no longer require
that homeowners provide evidence of discharge or dismissal to qualify.
Outreach
Q1: Please explain how the program will target outreach and provide access to
homeowners with limited English proficiency.
Q2: Please explain how the program will provide culturally relevant marketing.
A1: Targeted outreach will be built into the program. Temporary and permanent Intake
centers will assist homeowners with the application and collection of supporting
documentation. Additional statewide targeted outreach will take place in the form of a
grassroots approach backed by data analytics to focus efforts in areas deemed to be
the most susceptible to home displacement. In order to be on the forefront of
advocating for the distribution of HAF funding specifically to reach those socially
underserved and disadvantaged communities, DEO will utilize the data gathered to
identify which communities have homeowners who are disproportionately impacted.
DEO will then target those populations with priority to drive participation and increase
access to the program’s funding across applicable qualified expense categories.
Teams will conduct targeted canvassing and marketing efforts, if necessary, to seek
out those identified as hard to serve due to social, language, and economic barriers.
For past efforts in reaching homeowners in need, digital advertising was the most
successful paid advertising in terms of statewide outreach, cost, and return on
investment. TV and radio advertising had a much higher cost per applicant. However,
based on some of the state’s rural counties, both paid and public service
announcement placements on rural radio stations and in local publications will be
explored to reach socially disadvantaged individuals who may be among those lacking
internet access.
The following organizations assisted DEO with identifying the program’s targeted
population:
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• Florida Housing Finance Corporation
• US Bank
• Wells Fargo
• Citizens Property Insurance Corporation
• Duke Energy
• Florida Power and Light / Gulf Electric
• Tampa Electric Company
• Florida Electrical Cooperative Association
• Legal Aid of Broward
• Florida Association of Court Clerks and Comptrollers
• National Housing Policy Council
• Florida DEO Bureau of Workforce Statistics and Economic Research
• Community Action Agencies (Florida Association for Community Action)
• Florida Housing Counselor Network
A2: Non-traditional outreach may prove to be more effective in reaching targeted
populations. Based on guidance from local partners on what will work best in their
communities, different methods may be utilized. DEO’s vendor is compiling a growing
list of organizations and stakeholders who serve the geographic areas, or the
demographic groups identified for enhanced culturally relevant outreach. DEO will
provide more information on successful avenues of outreach as they are identified.
Prioritization
Q: If your program intends to serve households who are over the 100% AMI threshold, how
will your program prioritize Socially Disadvantaged Individuals?
A: Florida will target at least 70% of HAF funds toward recipients whose incomes are less
than or equal to 100% of the AMI. For any HAF program funds not used for recipients
whose incomes are less than or equal to 100% of the AMI, Florida will prioritize funds
to Socially Disadvantaged Individuals
1
in its review and approval of applications.
1
“Socially Disadvantaged Individual” means an individual who (i) identifies as Black American, Hispanic American, Asian American
or Native American (i.e., Alaska Native, Native Hawaiian, or an enrolled member of a Federally or State recognized Indian Tribe);
(ii) has limited English proficiency; (iii) is a resident of a majority-minority Census tract; or (iv) lives in a persistent-poverty county
(i.e., a county that has had 20% or more of its population living in poverty over the past 30 years as measured by the three m ost
recent decennial censuses). If the individual who is applying for the HAF Program attests that he or she is a “socially disadvantaged
individual” pursuant to clause (i) or (ii) or DEO verifies that the household qualifies pursuant to clause (iii) or (iv), then the household
will qualify for “Socially Disadvantaged Individual” targeting.
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Performance Goals
Q: Please explain how you intend to communicate your progress towards performance to
the public.
A: Communication on the progress of the HAF program’s performance may be provided
through multiple outlets that include, but are not limited to the following: emails, press
releases, presentations, stakeholder outreach, and social media. DEO will also keep
stakeholders updated throughout the process and request feedback to constantly
improve outreach and services to Floridians.
Q: Please indicate which three metrics will serve as the best indicators of the success of
your program.
A: The following metrics will serve as the best indicators of the success of Florida’s HAF
program:
1. The number of eligible homeowners served by the HAF assistance.
2. The efficiency and speed from homeowner application to payment disbursement.
3. The diversity of services/eligible expenses disbursed for Florida homeowners.
Q: Please indicate whether you intend to disaggregate metrics by income, race, gender,
etc.
A: The state of Florida intends on disaggregating data by income and race.
Q: Please consider including as an additional metric the number of homeowners
assisted/foreclosures prevented solely through counseling or legal services without
payment of HAF funds to resolve the homeowner’s defaults or delinquencies.
A: The state of Florida will aggregate this data.
Readiness
Q: Please provide the most recent available information about your program's readiness,
including staffing, contractors, etc.
A: After the state of Florida submitted its HAF Plan, DEO launched a formal solicitation
to retain a vendor. Once Florida’s HAF Plan is approved by the U.S. Treasury, DEO
will promptly begin implementing the HAF Plan with its vendor.
DEO has dedicated internal project managers assigned to the HAF program. As
needed, DEO will hire additional project managers.
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Furthermore, DEO, as a state agency, has the infrastructure to provide support for the
HAF program, including information technology, finance and accounting, legal,
communications, and marketing.
Q: Is your program prepared to launch upon approval and, if not, by what date will you be
ready to launch following approval?
A: Yes, the state of Florida and DEO are prepared to launch the program immediately
following approval of the HAF Plan by the U.S. Treasury.
Q: Please provide updated information about your progress in spending the initial 10%
payment from your jurisdiction’s full allocation and the status of any pilot assistance
already offered or made available to homeowners.
A: The state of Florida launched its HAF Mortgage Assistance Pilot Program on
November 8, 2021 and has encumbered approximately $1 million in assistance to
Florida homeowners. As we began implementing the Pilot Program, the rate of
mortgages being modified by the lender accelerated to the point where there are
only a handful of loans in their portfolios that have not completed loan modifications.
Our experience with the Pilot Program has brought into focus the importance of
future payments to help provide long-term housing stability to low- and moderate-
income homeowners. As a result of the loan modifications, the HAF Pilot Program
pivoted to focus on homeowner insurance and homeowner utility arrearages. In the
coming weeks, the Pilot Program will be expanded to include these qualified
expenses.
Budget
Q: Your plan indicates the following program design elements will be offered with no
corresponding budget allocation. Please provide a budget allocation by each program
design element. Alternatively, you may group similar types of program design elements,
i.e., mortgage-related program design elements (i.e., payment assistance, principal
reduction, or reinstatement), taxes and insurance (outside of mortgage), etc.
A: Based on discussions with the U.S. Treasury regarding the budget structure, DEO
has decided that grouping similar types of programs would allow the state to more
effectively serve homeowners in need. The budget is as follows:
• Mortgage Assistance, down payment loan assistance, and commonly escrowed
expenses:
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$494,687,023
2
• Payment Assistance for Internet, Utilities, and HOA Liens and Fees:
$60,000,000
3
• Housing Counseling and Educational Services:
$20,000,000
Q: Please provide your rationale for not providing funding for legal services to assist
homeowners.
A: Based on public comments received, the state of Florida expects that housing
counseling and other educational services will provide more effective assistance in
guiding homeowners toward housing stability, loss mitigation and overall a path to
financial stability as opposed to legal services.
2
Includes Mortgage Payment Assistance, Mortgage Reinstatement, Delinquent Property Taxes, Future Property
Taxes, Homeowner’s Insurance, Down Payment Assist Loans
3
Includes Homeowner’s Internet Service, Utilities, and HOA Liens and Fees
