Housing Stability Counseling Program

A federally funded program designed and administered by NeighborWorks® America

May 26, 2021 (Updated September 7, 2021)

Table of Contents Purpose of Funding ...... 2 Definitions ...... 2 Funding Available ...... 5 HUD-Approved Agencies/HUD-Certified Counselors ...... 6 Eligible Applicants ...... 7 Applicants with Multiple Affiliations ...... 9 Eligible Activities ...... 10 Application Summary and Scoring...... 18 Funding Time Frame ...... 21 Disbursement Schedule ...... 22 Other Program Requirements ...... 24 Post-Award Requirements ...... 27 Exhibit 1: HSCP Targeting Methodology ...... 29 Exhibit 2: HSCP Minimum HUD Approval Standards ...... 43 Exhibit 3: Draft HSCP Client Level Data Reporting Requirements ...... 44 Exhibit 4: HSCP Award Disbursement Requirements ...... 50

Page 1 of 50 Housing Stability Counseling Program Funding Announcement Program administered by NeighborWorks® America

Purpose of Funding

On March 11, 2021, President Biden signed the American Rescue Plan Act of 2021 (Public Law 117-2) into law, appropriating $100 million to the Neighborhood Reinvestment Corporation, doing business as NeighborWorks® America (NeighborWorks), to fund the Housing Stability Counseling Program (HSCP). These funds are for housing counseling services, defined as (i) housing counseling provided directly to households facing housing instability, such as eviction, default, foreclosure, loss of income, or homelessness; (ii) education, outreach, training, technology upgrades, and other program related support; and (iii) operational oversight funding for grantees and sub-grantees. With this Funding Announcement, NeighborWorks makes available up to $88.5 million in grant funds.

HSCP is intended to support the delivery of housing counseling services by HUD-Approved Housing Counseling Intermediaries, State Housing Finance Agencies, NeighborWorks Organizations, and the housing counseling agencies with whom they subgrant or contract. Grant funds will be awarded to Applicants with demonstrated experience in providing housing counseling services to households facing housing instability.

The statutory authority for HSCP mandates that a minimum of 40 percent of funds shall be provided to counseling organizations that target housing counseling services to minority and low- income populations facing housing instability or provide housing counseling services in neighborhoods having high concentrations of minority and low-income populations. The statutory language that governs the program can be found at www.stablecommunities.org.

NeighborWorks reserves the right to amend the guidelines set forth in this Funding Announcement. Any questions about HSCP should be directed to [email protected].

The performance period for HSCP is from the date of grant agreement issuance through February 28, 2023. All HSCP funds shall be expended by February 28, 2023.

Definitions

1. Affiliate. An “Affiliate” is a Sub-grantee of a HUD-Approved Housing Counseling Intermediary (Intermediary) or State Housing Finance Agency (SHFA) which is incorporated separately from the Intermediary or SHFA. An Affiliate is: (1) duly organized and existing as a 501(c)(3) nonprofit organization, (2) in good standing under the laws of the state of the organization, and (3) authorized to do business in the states where it provides or proposes to provide housing counseling services. For the purposes of this Funding Announcement, Affiliates are identified as “Sub-grantees.”

2. Applicant. ‘‘Applicant’’ refers to an Intermediary, SHFA or NeighborWorks Organization (NWO) with demonstrated experience in providing housing counseling services to households facing housing instability.

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3. Branch. A “Branch” or “Branch Office” is an organizational and subordinate unit of an NWO, or a Sub-grantee of an Intermediary or SHFA which is not separately incorporated or organized. For the purposes of this Funding Announcement, Branches are identified as “Sub-grantees.”

4. Contracted Counseling Entity. A “Contracted Counseling Entity” (CCE) is a Housing Counseling Agency that a NWO has contracted with to deliver HSCP-funded housing stability counseling services, and which is accountable to the NWO Grantee for the use of the funds provided.

5. Demonstrated Experience (Revised 6/11/2021). "Demonstrated Experience" refers to an Applicant's successful and recent track record from November 1, 2019 to April 30, 2021 with providing housing stability counseling services for households facing housing instability such as eviction, default, foreclosure, loss of income, or homelessness. To qualify as having demonstrated experience, an Applicant and all sub-grantees or CCEs that will receive funding must have:

• Worked successfully with landlords, lenders and/or servicers, and with clients in threat of or facing eviction, foreclosure and/or homelessness; AND • Documented counseling capacity, outreach capacity, past successful performance, and positive outcomes with documented counseling plans and housing stability counseling outcomes (e.g. landlord and rental agreements, loan workouts, loan modification agreements or foreclosure resolution outcomes); AND • Certified that at least one of the following is true for it and each sub-grantee or CCE that will receive HSCP funding:

a) Has provided housing stability counseling services with documented action plans to at least 30 people in the past year (If less than 30 served, select this option if the agency can’t certify to option b below). In the narrative section describing past performance in the grant application, the agency can detail their experience serving clients even if it is less than 30. OR b) 75% or more of its service area is in a rural area (if your organization is serving a community that is eligible for USDA Rural Development programs and services as of June 30, 2021, your organization may count that community as rural for the purposes of this application) AND it provided housing stability counseling which included documented action plans to at least 15 people during the past year or 10 people during the most recent quarter.

6. Grantee. ‘‘Grantee’’ refers to the Intermediary, SHFA, or NWO that applies for and receives a direct HSCP grant award.

7. Housing Counseling Agency (HCA). A “Housing Counseling Agency” or “HCA” provides housing stability counseling as a Sub-grantee or CCE of a Grantee. An HCA may have a main office, and one or more branch offices. The HCA is either a HUD-Approved Housing Counseling Agency or meets the minimum standards, as identified by HSCP, to receive HUD approval (See Exhibit 2 for the HSCP minimum HUD approval standards).

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8. Housing Counselor (Counselor). A “Housing Counselor” or “Counselor” is a professional who will provide housing stability counseling and is a HUD-certified counselor or actively working towards HUD counselor certification. Applicants will be required to identify all counselors (directly employed by the Grantee, Sub-grantees and/or CCEs) and their HUD counselor certification status.

If the counselor is not HUD-certified by the HSCP application due date of June 30, 2021, the Applicant must identify trainings the counselor has or will take towards certification and the date during the HSCP performance period that the HUD certification exam will be taken. Grantees, Sub-grantees and CCEs must maintain an accurate record of each counselor’s HUD certification status throughout the HSCP performance period. Grantees are responsible for updating HSCP throughout the performance period of HUD certification status for counselors working on HSCP.

9. Housing Stability Counseling. “Housing Stability Counseling” for the purpose of this Funding Announcement is housing counseling provided directly to households facing housing instability such as eviction, default, foreclosure, or loss of income that caused or could cause eviction, default, foreclosure or homelessness. Pre and post-purchase counseling is not an eligible counseling service for HSCP.

10. HUD-Approved Housing Counseling Intermediary (Intermediary). An “Intermediary” is a HUD-approved organization (Regional, National, and Multi-State) that provides housing counseling services directly and/or indirectly through its Sub-grantees, for whom it exercises control over the quality and type of housing counseling services rendered. Intermediaries (Regional, National, and Multi-State) must have received HUD approval by 8:00 p.m. EST on June 30, 2021 to be considered for funding.

11. Low-Income. A renter or homeowner is considered “Low-Income” if the household earns less than 80% of the Area Median Income (AMI) based on the location of their primary residence. Each area’s AMI is calculated annually by the U.S. Department of Housing and Urban Development (HUD) based on household size and income. Area Median Income information can be found at www.huduser.gov AMI portal.

12. NeighborWorks Organization (NWO). A NeighborWorks Organization (NWO) is a chartered member of the NeighborWorks network. NWOs can apply for HSCP funds directly as stated in the authorizing legislation. NWOs rated “Vulnerable” may apply but will require an exception from their Regional NeighborWorks Senior Vice President to receive funds. NWOs rated “Provisional” are not eligible to apply.

13. Online Reporting System (ORS). The “Online Reporting System” is NeighborWorks’ online data collection and reporting system. HSCP Grantees will report client-level data and quarterly reports utilizing the ORS, which will be available October 1, 2021. NeighborWorks will provide an Excel template and Data Dictionary which must be followed to successfully report data into the ORS. Data can also be entered manually.

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14. State Housing Finance Agency (SHFA). A “State Housing Finance Agency” or “SHFA” is the public body or agency that is an instrumentality created by a specific act of a state legislature, empowered to conduct finance activities designed to provide housing and related services, for example land acquisition, construction, or rehabilitation, throughout an entire state. SHFAs may provide direct counseling services and/or sub-grant housing counseling funds to Sub- grantees within the SHFA's state. “State” includes the states, Puerto Rico, the District of Columbia, Guam, the Commonwealth of the Northern Mariana Islands, American Samoa and the U.S. Virgin Islands.

15. Sub-grantee. “Sub-grantee” refers to an organization (such as a Branch or Affiliate) to which an Intermediary or SHFA Grantee awards a sub-grant, and which is accountable to the Grantee for the use of the funds provided. All Sub-grantees must either be a HUD-approved Housing Counseling Agency or meet the minimum standards, as identified by HSCP, to receive HUD approval (See Exhibit 2 for HSCP minimum HUD approval standards). Grantees are responsible for ensuring that all Sub-grantees adhere to the standards set forth in this Funding Announcement and the HSCP Grant Agreement and agree to oversee the quality of services and adequacy of record keeping for each.

Funding Available Available funds will be awarded through a competitive grant process and disbursed upon execution of a Grant Agreement, as outlined in this Funding Announcement. Of the available grant funds, 40% will be awarded to Applicants that target housing counseling services to minority and low- income populations facing housing instability or provide housing counseling services in neighborhoods having high concentrations of minority and low-income populations. No more than 15% of the grant funds awarded shall be awarded to NWOs as direct Grantees.

In the event that additional funds become available for HSCP through additional appropriations from the U.S. Congress or through reallocation of unawarded, undisbursed, recaptured, or de-obligated HSCP grant funds, NeighborWorks reserves the right to make additional awards under the applications solicited by this Funding Announcement, giving priority to Grantees that have met or exceeded their goals for providing housing stability counseling services to minority and low-income populations facing housing instability and/or in neighborhoods having high concentrations of minority and low-income populations. (See Exhibit 1 for the HSCP Housing Instability Index that captures low-income, minority populations and neighborhoods with high concentrations of minority and low-income populations facing housing instability).

Anticipating extremely high demand for these funds and recognizing the need to ensure housing stability counseling services are available across the country, particularly targeting counseling services to minority and low-income populations and/or in neighborhoods having high concentrations of minority and low-income populations facing housing instability; NeighborWorks has imposed minimum and maximum amounts of HSCP grant requests. No one Applicant can request a total award of more than $10,000,000 and no one Applicant can request a total award of less than $50,000.

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Depending on demand for available funding, NeighborWorks reserves the right to establish award limits lower than both the maximum and minimum request amounts during the grant review and award process. NeighborWorks also reserves the right to award Applicants less than their full funding request.

Applicants should only apply for the amount of funding they have the capacity to manage or spend down by February 28, 2023.

Award decisions will be based on a number of considerations, including (without limitation): (1) the recommendations and scores of grant reviewers with particular attention to the reasonableness of the Applicant’s housing stability counseling goals, based on the rationale as described in its application and its Demonstrated Experience, as well as its capacity to deliver housing stability counseling services and/or manage multiple Sub-grantees or CCEs if applicable; (2) geographic diversity, including services to minority and low-income populations or housing counseling services in neighborhoods having high concentrations of minority and low-income populations facing housing instability; and (3); total demand for funding from all Applicants. In making award decisions, NeighborWorks may rely on information not contained in Applicant’s submitted application, including Applicants’ previously submitted HUD Housing Counseling Agency Activity Reports (HUD 9902s), if applicable; findings from HUD Housing Counseling performance reviews, if applicable; financial audit reviews; and other available relevant information.

It is important for Grantees to understand the rules and requirements of all federal funds awarded, particularly regarding billing multiple programs for the same clients. For the purposes of the HSCP grant award, Grantees are required to maintain a separate budget and segregate HSCP funds and should document when the cost of counseling HSCP households exceeds the maximum amount reimbursable per household. HSCP Grantees will not be allowed to bill for the same client more than once for counseling services. Recognizing that some clients who have received HSCP-funded counseling may experience new circumstances threatening their ability to retain housing stability, Grantees will be required to document the additional cost associated with longer-term counseling and bill to other allowable sources. HSCP will not limit Grantees’ ability to bill other allowable sources for the same client if the cost of counseling exceeds the amount of funding provided through HSCP, however the Grantee is responsible for identifying other allowable sources requirements.

HUD-Approved Agencies/HUD-Certified Counselors HSCP values HUD-Approved Counseling Agencies and HUD-certified counselor certification. It recognizes that professional and experienced Housing Counseling Agencies and counselors that are providing critical housing stability counseling services to low-income and minority populations and neighborhoods with high concentrations of low-income and minority populations facing housing instability might not yet be HUD approved or are actively working towards HUD counselor certification. Applicants will be required to provide, at the time of application, a list of all of its Sub-grantees, CCEs and counselors. HSCP will require Applicants to meet the following standards:

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1. HUD-Approved Agencies HSCP Applicants must be HUD-Approved Housing Counseling Agencies or certify that they meet the minimum standards, as identified by HSCP for HUD-approval (See Exhibit 2 for the minimum HUD-approval standards for HSCP). Grantees will be required to maintain HUD-approval and counselor certification or meet the HSCP minimum HUD- approval standards as identified by HSCP throughout the HSCP performance period and must notify HSCP of any changes immediately. Failure to do so may result in de-obligation and/or recapture of HSCP grant funds.

2. HUD-Certified Counselors All counseling provided through HSCP , whether provided by Grantees, counselors employed directly by Grantee, or counselors employed by Sub-grantees or CCEs, must be provided by HUD-certified counselors or counselors actively working towards HUD certification. HSCP will provide preference points for Applicants if 75% or more of its counselors providing services under HSCP are HUD-certified counselors. If the counselor is not HUD-certified at the time of the HSCP application, the Applicant must identify in the application the trainings the counselor has taken or will take towards certification and the date during the HSCP performance period that the HUD certification exam will be taken. Grantees, Sub-grantees and CCEs must maintain an accurate record of counselors and their HUD counselor certification status throughout the HSCP performance period. Grantees are responsible for updating HSCP throughout the grant award performance period of any changes to counselors working on HSCP and their HUD certification status.

Grantees are directly responsible for ensuring the quality of counseling to households facing housing instability. Failure to ensure that counselors are HUD-certified or regularly check the status of counselors working towards becoming HUD-certified may result in de- obligation and/or recapture of HSCP grant funds.

Eligible Applicants

The HSCP Eligible Applicants are as follows:

1. HUD-Approved Intermediaries (Regional, National, and Multi-State) that have been HUD approved by 8:00 P.M. EST on June 30, 2021. Prospective HUD-Approved Intermediaries should note that HUD’s approval process can take up to two months and therefore it may not be possible to complete the process in time to apply for this funding opportunity.

2. SHFAs which have statutory authority to operate as a SHFA, to serve the entire state, and to apply for and subsequently use any funds received. Only one SHFA per state shall receive an award through HSCP .

• Intermediary and SHFA Applicants will identify the delivery of housing stability counseling services by: (a) applying for funds on behalf of a network of Sub-grantees; or (b) providing counseling directly through its employees.

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• Intermediaries and SHFA Applicants will be required to detail the Demonstrated Experience that refers to an Applicant’s successful and recent track record from November 1, 2019 to April 30, 2021 with providing housing stability counseling services for households facing housing instability such as eviction, default, foreclosure, loss of income, or homelessness.

• Intermediaries and SHFAs must demonstrate the capacity required to distribute funds, monitor compliance, communicate regularly, collect requisite data that includes program outcomes, and monitor and ensure the quality of counseling and overall performance of each Sub-grantee that will provide services through HSCP.

• Sub-grantees of Intermediaries and SHFAs are required to be a HUD-Approved Housing Counseling Agency or meet the HSCP minimum HUD-Approval Standards, which can be found in Exhibit 2.

• All counselors utilizing HSCP funds to provide counseling, including direct employees of the Intermediary or SHFA and those of its Sub-grantees, must be a HUD-certified counselor or actively working towards passing the HUD certification exam. Intermediaries and SHFAs, at the time of application, must identify the HUD _Certification status of all of its counselors.

• Grantees, direct employees and Sub-grantees providing counseling utilizing HSCP funds must maintain an accurate record of counselors and their HUD certification status throughout the HSCP performance period.

• Intermediaries and SHFAs are permitted to add or remove Sub-grantees during the performance period by submitting an updated list via email to NeighborWorks at [email protected]. Adding Sub-grantees does not result in an increased grant award.

3. NeighborWorks Organizationsare existing chartered members of the NeighborWorks network. NWOs must obtain their NeighborWorks charter on or before 8:00 p.m. EST on June 30, 2021 to be eligible. NWOs rated “Vulnerable” may apply but will require an exception from NeighborWorks to receive funds. NWOs rated “Provisional” are not eligible to apply.

• NWOs may contract with CCEs to provide housing stability counseling, provided that such arrangements are made on a contractual basis and no more than 50% of the awarded counseling services shall be contracted out.

• As part of their application, NWOs will be required to identify all CCEs and if they are HUD-Approved Housing Counseling Agencies or meet the HSCP minimum HUD_Approval_Standards to become HUD-Approved.

• All counselors utilizing HSCP funds to provide counseling, including direct employees of the NWO and those of its CCEs, must be a HUD-certified counselor or actively

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working towards passing the HUD certification exam. NWOs, at the time of application, must identify the HUD _Certification status of all of its counselors.

Grantees will be required to maintain updated records of HUD-Approval status, certification of meeting HSCP minimum HUD-Approval standards and HUD certification status of its direct employees and employees of its Sub-grantees or CCEs throughout the HSCP performance period. Grantees that fail to retain these records may be subject to de-obligation and/or recapture of HSCP grant funds.

Applicants with Multiple Affiliations Due to the critical need of households across the country facing housing instability, HSCP will allow Applicants to provide services as a direct Grantee and apply to provide services as a Sub- grantee or CCE of another Applicant. Sub-grantees and CCEs are also eligible to apply under multiple direct grantees. Applicants must identify at the time of application if they will receive direct funds and work as a Sub-grantee or CCE as well as identify if any of their Sub-grantees or CCEs will have multiple affiliations:

Direct Grantees Multiple Affiliations

Intermediaries, SHFAs and NWOs, as direct Applicants, may elect to participate in this program as a direct Grantee and as a Sub-grantee or CCE of a direct Grantee:

a) Applicants must disclose that they are applying as a direct Grantee and as a Sub-grantee or CCE of multiple Applicants, and identify the direct Applicant; AND

b) Justify why applying as a direct Grantee and Sub-grantee or CCE of another direct Grantee is critical to meeting the demand for housing stability counseling in its service area; AND

c) Demonstrate capacity to track and report the various contracted activities as a direct Grantee and a Sub-grantee or CCE of another direct Grantee, which includes but is not limited to the ability to report client-level data with unique identifiers to prevent duplication of billing for the same client and manage funding under multiple contracts.

Sub-grantees and CCEs with Multiple Affiliations

Direct Applicants must disclose when its Sub-grantees or CCEs are applying under multiple affiliations:

a) Applicants must disclose when a Sub-grantee or CCE is contracted/providing counseling services under HSCP with multiple direct Applicants; AND

b) Justify why its Sub-grantee or CCE is applying for HSCP funds under multiple direct Applicants is critical to meet the demand for housing stability counseling in their service area; AND

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c) Demonstrate their capacity to track and report the various contracted activities under multiple affiliations as a Sub-grantee or CCE, which includes but is not limited to the ability to report client-level data with unique identifiers to prevent duplication of billing for the same client and manage grant award funds under multiple contracts.

Direct Applicants should ensure they have the capacity and ability to report under multiple programs. If a direct Applicant falls below its required goals from their grant award, it will be subject to de-obligation and/or recapture.

Eligible Activities No funds made available under HSCP may be provided directly to financial institutions, lenders, servicers, landlords, property management companies, renters or homeowners to discharge outstanding rent or mortgage balances or for any other direct debt reduction payments. These funds may only be used to provide housing stability counseling services.

All Grantees will maintain a separate budget and segregate HSCP funds from other sources of funds. The HSCP grant award must be used to fund Grantees’ housing stabilization efforts and related expenses. Grantees are responsible for monitoring the expenditures of its Sub-grantees or CCEs to ensure the HSCP funds are being used toward eligible expenses for Counseling, Program Related Support and Operational Oversight, if applicable. In the final report, all Grantees will report on the expenditures of HSCP funds. Grantees will report in the aggregate for its Sub- grantees or CCEs and should ensure they can furnish documented evidence during the course of HSCP planned quality control and compliance measures.

All HSCP funds must support the costs of overall housing stability counseling services. If the cost of the counseling is less than HSCP funding, Grantees do not need to return excess funds; rather, they must allocate those funds to their overall housing stability counseling program. NeighborWorks reserves the right to request documented evidence of the uses of excess funds.

HSCP eligible activities fall into three categories: (1) Counseling; (2) Program-Related Support; and (3) Operational Oversight, for Intermediaries and SHFAs only. Each category is defined in greater detail below. While Applicants are encouraged to apply for the amount of funding, they believe they can use before February 28, 2023, NeighborWorks reserves the right to award less than the amount requested.

1. Counseling

NeighborWorks has created a tiered structure for counseling services in which the client facing housing instability receives intake, triage and assessment, counseling services and follow-up. Applicants must certify they will provide all levels of counseling in their application and are expected to make best efforts to provide all levels of counseling to each client.

Counseling can include a range of activities depending on the client’s financial situation and the severity of their housing instability crisis. Clients in the early stages of housing instability may benefit from counseling sessions that result in an action plan they can follow to get back on track.

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Others will require assistance with complex workouts involving negotiations with landlords, financial institutions, lenders, servicers or other housing-related resources that require experienced and trained counselors with additional expertise. Their cases may take longer to resolve and require follow-up to ensure they are still on track and/or have resolved their housing instability crisis. Recognizing this, NeighborWorks has developed a tiered structure for defining and estimating the cost of counseling activities, as described below. Counseling awards as calculated for the HSCP application are based on the value of Level 1 intake/initial counseling set at $200, Level 2 counseling set at $550, and follow-up set at $50.

Counseling services can be provided to renters living in properties owned and operated by an Applicant, and homeowners holding mortgages, including second mortgages, originated or serviced by an Applicant. Please note that Grantees, Sub-grantees, CCEs and third-party vendors must operate in accordance with the HUD Handbook 7610.1. REV 5 6-2 Conflicts of Interest and 24 CFR 214.303(f). Agency staff, board, and immediate family members will not participate in any action that supports personal interests, activities, or relationships related to HSCP. Sufficient firewalls must be in place to assure that the counselors’ actions are not influenced by loss mitigation staff for lending, asset management functions or other personal gains.

Duplicate Billing HSCP Grantees will not be allowed to bill the same client more than once for any Level of counseling or follow-up. Recognizing that some clients who have received HSCP-funded housing stability counseling may experience new circumstances threatening their ability to remain current on their rent or mortgages, Grantees will be required to document the additional cost associated with longer- term counseling and bill to other allowable sources.

“Level 1” Intake and Initial Counseling: Level 1 services related to intake and triage do not need to be conducted by a Housing Counselor as defined in Definition 8 on Page 4 of this Funding Announcement; however, non-counselors should be trained to identify a crisis situation to note that Level 2 counseling should take place within two (2) business days from the date of intake and initial counseling. The dates of Level 1, and if needed, Level 2 counseling should be noted on the Action Plan along with the date of follow-up. Examples of a crisis situation may include a pending eviction, a pending foreclosure sale date, insufficient funds to cover basic needs such as utilities or medications, or other situations identified by the client and/or agency. A crisis budget should include plans to prioritize immediate needs such as shelter, transportation, medications, utilities, etc. A sample Crisis Budget can be found on the HSCP Resources Page. . Services related to creating a client’s budget and action plan must be conducted by a Housing Counselor as defined in Definition 8 on Page 4 of this Funding Announcement. To qualify for a Level 1 payment ($200), a counseling agency will be required to complete all of the following steps:

1. Intake. Organization must conduct an intake and collect information including client name and address, basic demographic information, lender and loan information, landlord and lease information, reason for housing instability and other housing instability related documentation. Organization must also collect documentation (must be within 30 days of intake date) of all reasonable opportunities for income including but not limited to: unemployment and other public benefits, tax returns, pay stubs, profit and loss statements and third-party verifications; and expenses, including but not limited to: mortgage

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statement, rental lease agreement, monthly bills, bank statements, credit card statement and utility bills. Note: a credit report alone does not satisfy the budget requirement. Any client communication with landlord/servicer must also be collected, if applicable, to determine the urgency and severity of the client’s need, including but not limited to an eviction notice, Notice of Default, or Notice of Sale.

HSCP Grantees will ensure that the lack of financial documentation or communication from the landlord, lender or servicer does not create a barrier to counseling. If the client has not received communication from the landlord, lender or servicer, the counselor or intake staff must clearly outline the assessment and detail the reason for counseling in the Action Plan. Grantees will be allowed to report Level 1 client-level data once the majority of financial documentation is included in the client’s file.

2. Authorization. Organizations must collect a signed authorization form from the client or have other legally-permissible client authorization on record that will allow the organization to (a) pull a credit report at intake (it is recommended, but not required, that credit scores are procured with the credit report); (b) submit client-level information to the ORS for this grant, (c) allow HSCP to open files to be reviewed for program monitoring and compliance purposes, and (d) allow HSCP to conduct follow-up with the client related to program evaluation. Clients may opt out of (a) if the client provides a credit report dated within 30 days of the intake date. Clients can also opt out of (d) but proof of this must be retained in the client’s file. Clients that opt out of (a) and do not have a credit report that was dated within 30 days of the intake date or opt out of (b) or (c) cannot be reported to the ORS for payment by HSCP.

NeighborWorks has made available a template authorization form for Grantees to modify for their own use if they do not already have such a form. Alternatively, Grantees may incorporate the language above into their existing authorization forms. Clients reported to the ORS without a signed authorization form can create a legal liability for a Grantee; therefore, Grantees must ensure clients reported to the ORS have a signed authorization form in the client file. It is acceptable for Grantees to substitute the words “Grant Administrators” or “Funders” in place of “HSCP” in (c) or (d) above.

Grantees are responsible for performing HSCP services within the limits of the laws in the state(s) in which they operate. If agencies are providing HSCP services via telephone or online, they should verify verbal/electronic authorization laws in the state(s) where the counseling will be performed. They should also maintain proof of electronic signature or verbal authorization in each client file, as permissible by the law in the state(s) in which they operate.

3. Disclosure. Organization must provide to all clients a disclosure statement. The disclosure statement must explicitly describe the various types of products and services the organization provides and any financial relationships between the Grantee, Sub-grantee or CCE, and any other industry partners. The disclosure must state clearly that the client is not obligated to receive any other services offered by the Grantee, Sub-grantee or CCE, its exclusive partners, or third-party entities to which a client is referred for additional services. This must be presented to the client at the time of intake. Proof that the client received the

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disclosure must be maintained in their file. Such proof must be signed by the renter/homeowner and can include an electronic signature.

4. Privacy Policy. Organization must provide to all clients a copy of its privacy policy. Proof that the client received the policy must be maintained in the file. Such proof can include a statement signed by the client indicating receipt or an electronic signature, if applicable. If the policy is mailed to the client, the Grantee must keep on file proof that the policy was sent to the client via email or postal mail. Having access to the privacy policy on the organization’s website does not satisfy this requirement unless there is affirmative confirmation and documented proof that the client has reviewed the policy in the file. Please note that clients who are given the choice to “opt-out” of the organization’s privacy policy provision allowing for the sharing of their information with affiliated third parties and choose to do so cannot be reported to the ORS for payment by HSCP.

Note: it is acceptable for organizations to combine the authorization form, disclosure statement, and privacy policy into a single document as long as the client signs the document and the agency retains a copy in the client file.

5. Triage. Organization must assess each client’s situation with respect to severity/urgency. It is a best practice and HSCP strongly encourages Grantees to ensure a client with an eviction notice, Notice of Default, or Notice of Sale has direct communication with a counselor within 48 business hours of their request. The severity of the client’s situation should be noted in the Action Plan.

6. Budget. Organization must develop a budget with the client based on the client’s oral representation of their expenses, debts, and available sources of income. One example of a worksheet Grantees may use to develop this budget can be found at www.stablecommunities.org.

7. Action Plan. Organization must work with the client to develop a written Action Plan for steps to be taken. The Action Plan must be clearly labeled in the client file. When developing the Action Plan, it is expected that the counselor will do a comprehensive analysis of the client’s situation and recommend potential actions to be taken. The Action Plan must include the counselor’s assessment of the client’s situation with a client-specific recommendation for a counseling plan of action. A general handout with a variety of workout options or “Actions” is not acceptable. If the assessment and recommendation are part of the counselor notes, HSCP requires that the information be transferred to a form titled Action Plan so that the assessment and course of action are clearly defined for the client and for compliance testing. HSCP has also created template Action Plans and provided additional resources at www.stablecommunities.org. Use of these templates is not required; however, Grantees must have a conforming Action Plan in each client file.

When reporting for Level 1 counseling activities, all six of these completed documents must be in the client’s file: intake, authorization, disclosure, privacy policy, budget, and action plan. Grantees are responsible for ensuring proper documentation exists in client files of each of its Sub-grantees’ and/or CCEs.

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“Level 2” Counseling: Level 2 counseling services must be provided by a Housing Counselor as defined in Definition 8 on Page 4 of this Funding Announcement. To qualify for a Level 2 payment ($550), a counseling agency will be required to complete the following steps:

1. Authorization. Organization must collect a signed authorization form from the client or have other legally-permissible client authorization on record that will allow organization to (a) pull a credit report at intake (it is recommended, but not required, that credit scores are procured with the credit report); (b) submit client-level information to the ORS for this grant, (c) allow HSCP to open files to be reviewed for program monitoring and compliance purposes, and (d) allow HSCP to conduct follow-up with the client related to program evaluation. Clients may opt out of (a) if the client provides the credit report dated within 30 days of the intake date and (d) only, but proof of this must be retained in the client’s file. Clients that opt out of (a) and do not have a credit report that was dated within 30 days of the intake date or opt out of (b) or (c) cannot be reported to the ORS for payment by HSCP. NeighborWorks has made available a template authorization form for Grantees to modify for their own use if they do not already have such a form. Alternatively, Grantees may incorporate the language above into their existing authorization forms. Clients reported to the ORS without a signed authorization form can create a legal liability for a Grantee; therefore, Grantees must ensure clients reported to the ORS have a signed authorization form in the client file. It is acceptable for Grantees to substitute the words “Grant Administrators” or “Funders” in place of “HSCP” in (c) or (d) above.

Grantees are responsible for performing HSCP counseling within the limits of the laws in the state(s) in which they operate. If agencies are providing HSCP counseling via telephone or online, they should verify verbal/electronic authorization laws in the state(s) where the counseling is being performed. They should also maintain proof of electronic signature or verbal authorization in each client file, as permissible by the law in the state(s) in which they operate.

2. Disclosure. If not already on file, organization must provide to all clients a disclosure statement. The disclosure statement must explicitly describe the various types of products and services the organization provides and any financial relationships between the Grantee, Sub-grantee or CCE, and any other industry partners. The disclosure must state clearly that the client is not obligated to receive any other services offered by the Grantee, Sub-grantee or CCE, its exclusive partners, or third-party entities to which a client is referred for additional services. This must be presented to the client at the time of counseling if not already on file. Proof that the client received the disclosure must be maintained in their file. Such proof must be signed by the renter/homeowner and can include an electronic signature.

3. Privacy Policy. If not already on file, organization must provide to all clients a copy of its privacy policy. Proof that the client received the policy must be maintained in the file. Such proof can include a statement signed by the client indicating receipt or an electronic signature, if applicable. If the policy is mailed to the client, the Grantee must keep on file proof that the policy was sent to the client via email or postal mail. Having access to the privacy policy on the organization’s website does not satisfy this requirement unless there is affirmative confirmation and documented proof that the client has reviewed the policy in the file. Please note that clients who are given the choice to “opt-out” of the organization’s

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privacy policy provision allowing for the sharing of their information with affiliated third parties and choose to do so cannot be uploaded into the ORS for payment by HSCP.

Note: it is acceptable for organizations to combine the authorization form, disclosure statement, and privacy policy into a single document as long as the client signs the document and the agency retains a copy in the client file.

4. Budget Verification. Counselor must engage in budget verification during which documented evidence provided by the client is reviewed to establish true debt obligations, monthly expenses and spending patterns, and realistic opportunities for income. The counselor is expected to conduct a financial analysis that leads to a recommendation for resolving the delinquency or determining options for financial assistance or alternative housing options. A credit report alone does not satisfy the budget verification requirement.

If the client is in crisis due to a pending eviction or foreclosure, loss of income or other emergency, the counselor will be required to develop a crisis budget. An example of a crisis budget can be found on HSCP’s website at www.stablecommunities.org.

5. Verification of Action Taken. Counselors should take appropriate action upon the steps outlined in the written Action Plan created during Level 1 services. Counselor must have documented evidence of “action” taken by or on behalf of the client. This requires more than the counselor’s notes; it also requires documentation that action took place, which could include but is not limited to the following:

a. Determine eligibility for rent relief, other financial assistance and/or public benefits, including but not limited to unemployment, Medicaid, utility assistance and Paycheck Protection Program (PPP) loans; and help the client complete and submit applications for such relief. b. Discuss eviction or foreclosure process and general rights; and make a referral to legal assistance when necessary. Referrals require documented evidence in the client file. c. Document an attempt to contact the landlord, servicer or lender via email, fax transmission receipt, or postal mail receipt. The outcome of all communication must be documented in the client file. d. Help the client draft and submit a hardship letter to the landlord or servicer that describes the client’s situation, reason for delinquency, factors that should be considered when developing a workout plan, an estimate of the housing cost the client can afford to pay, and timeframe for returning to full payments. e. If a workout is possible, help the client complete and submit forms required by the landlord or servicer to move forward with a workout plan, loan modification or other available program. Verification that documentation was submitted via fax transmission receipt, email, or postal mail must be retained in the client file. f. Assist in situations where the client elects to pursue new housing options, or must move into temporary or transitional housing, and document the assistance that took place and communication with pertinent parties via emails, fax transmission report, or postal mail. A referral list of real estate agents for a short sale, or other sale options, must include at least three real estate agents and the client’s signature stating they received the referral list. This signed referral list should be retained in the file. Please

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note that “referring” a client back to the landlord/servicer/lender is not considered a referral.

Note: Counselor Notes and/or telephone logs do not satisfy the requirement for documenting Verification of Action Taken, as neither provide verifiable proof that any action took place. Emails, mail receipts, fax transmission sheets or other signed verification that any action took place is required to be retained in the client file.

When reporting for Level 2 counseling activities, all five of the following completed documents must be in the client’s file: authorization, disclosure, privacy policy, budget, and verification of action taken.

“Follow-up” ($50): Recognizing that follow-up may occur 30 to 60 days following Level 1 or Level 2 counseling, Grantee can bill for follow-up separately. follow-up activities such as sending the follow-up letter or closing out the file does not need to be conducted by a Housing Counselor as defined in Definition 8 on Page 4, however please note counseling must be conducted by a counselor.

1. Counselor must make a reasonable effort to have follow-up communication with the client, to assure that the client is progressing toward their housing goals, to modify or terminate housing stability counseling, and to learn and report outcomes, if applicable. The counselor should conduct a follow-up session within the first 30 days following Level 1* or Level 2 counseling. If unsuccessful, after two attempts to conduct a follow-up session, the counselor must write a letter or send an e-mail to the client stating that such efforts have been made and inform the client that there is a need for follow-up communication. The letter must request that the client contact the housing counseling agency no later than 30 days from the date of the letter, to help the agency assess if additional client services are necessary to assist them in achieving their housing goals or if services should be terminated. All documentation for follow-up should be retained in the client file.

Issuing surveys to assess housing outcomes does not fully meet the requirement for client follow-up. Hiring a third-party agency to conduct follow-up services is prohibited.

*In some cases, a client may not return for Level 2 counseling. In this case the Grantee can bill for Level 1 and must also follow the requirements as noted for follow-up. In the cases where the client does return for Level 2 counseling, it is expected that follow-up is billed following Level 2 counseling.

2. Program-Related Support (PRS) – All Applicants are eligible Applicants will receive PRS funds valued at 30% of their Counseling award. PRS funds shall be used to increase housing stability program efficiencies. If the Applicant does not wish to use the full 30% on eligible PRS activities, it can use these funds to provide additional HSCP counseling. A plan for use of these funds, including the estimated costs of major line-item budget items, must be included with the application. SHFAs, Intermediaries and NWOs with CCEs must pass through all PRS funds to their Sub- grantees or CCEs unless they keep on file a justification for how retaining a portion of the funds will have a timely and positive impact on the capacity of Sub-grantees or CCEs to

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conduct housing stability counseling. If this is the case, no more than 50% of PRS funds allocated under this section can be held at the Intermediary, SHFA or NWO level. These funds are not intended to cover administrative costs; rather, they are meant primarily to support direct costs associated, as much as possible, with increasing the ability of Grantees, Sub-grantees and CCEs to effectively and efficiently provide quality housing stability counseling. Eligible uses of Program-Related Support funds include but are not limited to:

• Establishing a triage system that makes for more effective and efficient use of counseling time, so counselors are not scheduling and reserving time for clients seeking help with situations not related to housing instability. • HUD-certification training and exam fees for counselors. • Outreach, marketing and service delivery should be directed at populations least likely to seek counseling services. To do so, it may be necessary to broaden the target areas or provide translation and interpretive services in languages other than English to reach a greater variety of racial and ethnic minorities. • Outreach and communication efforts aimed at preventing “rescue” rent or mortgage scams directed at renters and homeowners. • Infrastructure development and communication to strengthen monitoring and oversight of Sub-grantees and CCEs. • Technology improvements for outreach, counseling, education, registration and other housing instability-related purposes. • Improving Grantee capacity and infrastructure for tracking and reporting data through upgrades to Client Management Systems and reporting systems/processes. • Costs related to hiring, orienting and training new counseling staff. • Purchasing or leasing equipment and software for counselors. • Collecting data and preparing quarterly reports and disbursement requests. • Quality control of the counseling function. • Other related services necessary to provide quality housing stability counseling.

Applicants may contract out part or all of the activities proposed under PRS but must demonstrate that their subcontractors have the required experience and expertise in the application.

3. Operational Oversight (OO) – Only Intermediaries and SHFAs are eligible Intermediaries and SHFAs are responsible for ensuring the appropriate use of its HSCP grant funds both as a direct Grantee and as it oversees its Sub-grantees. Intermediaries and SHFAs will receive Operational Oversight to cover quality control, day-to-day oversight and management of this grant award, and any required improvements to systems and infrastructure. Among other things, Intermediaries and SHFAs are responsible for communicating program requirements to all Sub-grantees, ensuring their compliance, and reporting on their behalf. HSCP Grantees submitting data to the ORS are responsible for verifying the integrity of the data and will be held accountable through HSCP compliance audits if findings are cited. OO funds are determined as follows: 7% of the first $2.5 million received under the Counseling category (or up to $175,000), and 5% of any amount over $2.5 million. If a Grantee does not wish to use the full amount on Operational Oversight, it can use these funds to provide additional HSCP counseling.

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Application Summary and Scoring The application must be completed online, using NeighborWorks’ Grants Portal. No paper applications will be accepted. The application will incorporate narrative responses and templates.

The full application is expected to be available in the Grants Portal on June 2, 2021, and will be due June 30, 2021 at 8:00 PM EST. No late applications will be accepted under any circumstance.

Eligible Intermediaries and SHFA Applicants interested in applying must submit a signed and dated in 2021 W-9 to [email protected] by Wednesday, June 2, 2021, in order to have access to NeighborWorks’ Grants Portal and the application. This is a requirement. A W-9 is available at www.stablecommunities.org. NeighborWorks organizations do not need to submit a W-9. If an eligible Intermediary or SHFA has received funds from NeighborWorks in the last 12 months or believes its 2021 W-9 is already on file with NeighborWorks, it can confirm this by emailing [email protected]. After the W-9 is submitted, an email will be sent to each Eligible Applicant informing them that their access to the Grants Portal and HSCP application has been granted.

Application Guide A comprehensive Application Guide will be published on www.stablecommunities.org. It is extremely important that Applicants refer to the Application Guide as they complete the application, as it provides specific information about the level of detail that should be included in each response. Application Scoring Award decisions will be based on a number of considerations, including (without limitation): (1) the recommendations and scores of grant reviewers with particular attention to the Applicant’s Demonstrated Experience and capacity to deliver housing stability counseling services and/or manage multiple Sub-grantees or CCEs, if applicable; (2) the reasonableness of Applicant’s housing stability counseling goals; (3) geographic diversity, including services to minority and low- income populations and housing counseling services in neighborhoods having high concentrations of minority and low-income populations facing housing instability; and (4) total demand for funding from all Applicants. In making award decisions, NeighborWorks may rely on information not contained in Applicant’s submitted application, including Applicants’ previously submitted HUD Housing Counseling Agency Activity Reports (HUD 9902s), if applicable; findings from HUD Housing Counseling performance reviews, if applicable; financial audit reviews; and other available relevant information.

Application consideration shall be divided into three categories:

1) Threshold Requirements – to be considered for funding, all of the following must be met: a. Applicant must certify that it conforms to the program requirements outlined in this Funding Announcement. b. Applicant must have Demonstrated Experience in delivering housing stability counseling services as described in Definition 5 on Page 3 of this Funding Announcement.

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c. SHFAs must have the statutory authority to operate as an SHFA, to serve the entire state, and to apply for and subsequently use any funds received. d. HUD must confirm Intermediaries’ status is “Approved” as of 8:00 PM EST on June 30, 2021. e. NWOs must have obtained their NeighborWorks Charter as of 8:00 PM EST on June 30, 2021. NWOs rated “Vulnerable” may apply but will require an exception from NeighborWorks to receive funds. NWOs rated “Provisional” are not eligible to apply. f. Applicant must employ Housing Counselors as defined in Definition 8 on Page 4 of this Funding Announcement.

2) Past Performance – will be worth 40% of the overall review team score and will include: a. Applicant’s demonstrated experience in providing housing stability counseling, including to minority and low-income populations, outreach efforts, and service delivery in languages other than English. b. Applicant’s description of challenges it has experienced in implementing housing stability counseling and actions taken to address these challenges. c. Systems and processes Applicant has established to ensure efficient program delivery, quality control of services provided, and adherence to program/grant requirements. d. Applicant’s past performance with the HUD Housing Counseling Program, including program findings and recaptured funds. e. Steps Applicant has taken to resolve findings from federal, state or other investigation(s) related to its housing stability counseling program or use of federal funds, if applicable. f. Applicant’s experience managing housing stability counseling programs. g. Applicant’s effectiveness in performing oversight responsibilities, including managing and passing funds through to a network of Sub-grantees or CCEs; ensuring quality control of services offered; and ensuring adherence to program requirements. h. HUD-certification status of Housing Counselors that will be providing services through HSCP; and number and experience of Housing Counselors. i. Applicant’s ability to ensure firewalls are in place to ensure there is no conflict of interest if counseling its own clients. j. Applicant’s financial management capacity as evidenced by review of audited financial statements, single-audit, management letters, management responses, and adequacy of corrective action plans, if applicable. k. Applicant is in “good standing” with HUD. l. Organizational health ratings of NeighborWorks organizations.

3) Performance Plan – will be worth 60% of the overall review team score and will include: a. Applicant’s plan to oversee Sub-grantees/CCEs, including ensuring quality counseling is provided and implementing accountability measures. b. Applicant’s service delivery model. c. Capacity of Applicant and Sub-grantees/CCEs to perform in HSCP, including plans for recruiting, training and retaining Housing Counselors; staffing structure; and capacity to track and report clients to NeighborWorks, including use of Client Management Systems. d. Applicant’s capacity to refer renters and homeowners to additional service providers when appropriate.

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e. Reasonableness of Applicant’s projected goals and capacity to provide all levels of housing stability counseling. f. Partnerships Applicant has established to ensure renters and homeowners are aware of the housing stability counseling services being offered. g. Applicant’s outreach plans and goals to provide service to low-income and minority populations facing housing instability and Targeted Geographic Areas as identified by HSCP. h. Applicant’s plan for use of Program Related-Support. i. Applicant’s plan for use of Operational Oversight, if applicable, including Applicant’s ability to track which of its Sub-grantees receive funds directly from HSCP or through another Applicant.

Award Amount Determination Reviewers will determine scores for each non-threshold category based upon a standard scoring rubric.

If the recommended aggregate award amount for all Applicants as determined by the reviewers’ scores exceeds the amount available to be awarded, HSCP may use one or more of the following steps to bring award amounts within the limits of available funding:

• Institute an overall award amount cap and floor any one Grantee can receive. • Place Applicants into tiers according to the date they are expected to spend down an HSCP award. • Apply across the board cuts.

NeighborWorks reserves the right to utilize all three or additional criteria if necessary.

All award decisions are final and cannot be appealed; however, if an Applicant requests a debrief in writing within 45 days of award announcements, NeighborWorks shall grant a meeting to discuss its application.

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Funding Time Frame The anticipated schedule for HSCP funding is listed below. All dates are subject to change. All changes will be announced at www.stablecommunities.com.

May 26, 2021 Funding Announcement Available June 2, 2021 Eligible Applicant Briefings June 2, 2021 Application Guides Available June 2, 2021 Applications available in the Grant Portal June 30, 2021 Application deadline 8:00 PM EST July 1, 2021 Application reviews begin

Within Quarter 3 of 2021 Award announcements posted at www.stablecommunities.com Grant award letters distributed. 15 days after Grant Agreements distributed announcements made 15 days after Grant Executed Grant Agreements due to NeighborWorks Agreements distributed

Rolling Initial disbursements sent to Grantees, as Grant Agreements and required start-up documentation are received. No HSCP funds will be disbursed until all contingency obligations are fulfilled, if applicable. Client-level production is uploaded, and funds are disbursed. Starting October 1, 2021 Disbursements are not tied to quarterly reporting; however, Grantees must be current with their quarterly reports in order for disbursements to occur. March 31, 2022 First quarterly report required – reporting period September 1, 2021 – February 28, 2022 June 30, 2022 Second quarterly report required – reporting period March 1, 2022 – May 31, 2022 September 30, 2022 Third quarterly report required – reporting period June 1, 2022 – August 31, 2022 December 31, 2022 Fourth quarterly report required – reporting period September 1, 2022 – November 30, 2022 March 31, 2023 Fifth and final quarterly report required – reporting period December 1, 2022 – February 28, 2023 June 30, 2023 Grantees’ final programmatic and expenditure report due Ongoing until Grantees must comply with program evaluation requests June 30, 2026

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Disbursement Schedule Please see Exhibit 4 for a complete explanation of HSCP disbursement release guidelines.

The disbursement schedule is designed to provide Grantees with sufficient up-front funds to strengthen their counseling capacity, while linking future disbursements to achievement of counseling goals. NeighborWorks reserves the right to adjust individual Grantees’ disbursement schedules and amounts at its sole discretion, for reasons including but not limited to if funds are being expended more slowly than projected or if an audit or compliance review provides reasons for a more conservative disbursement schedule to be implemented. Following NeighborWorks’ receipt of a fully executed Grant Agreement and related start-up documentation, funds will disburse as follows:

Disbursement Schedule for Counseling, PRS and OO

Disbursement 1 When Grantees have submitted their fully executed Grant Agreement and related start-up documentation, they will receive their first disbursement. This disbursement will be equal to 35% of the Counseling award, 70% of PRS, and 35% of OO if applicable.

Disbursement 2 – Grantees will be able to report to the ORS beginning October 1, 2021. When Grantees can demonstrate that they have counseled enough clients to total 35% of their counseling award dollar amount, they can request a second disbursement. This disbursement will be equal to 30% of the Counseling award, the remaining 30% of PRS, and 30% of OO if applicable.

Disbursement 3 When Grantees can demonstrate that they have counseled enough clients to total 65% of their Counseling Award dollar amount, they can request a third disbursement. This disbursement will be equal to 30% of the Counseling award and 30% of OO if applicable.

Disbursement 4 The final 5% of the counseling award, and OO if applicable, will be disbursed when the Grantee has counseled enough clients to total 100% of the counseling award dollar amount, completed its final report, and completed all organizational obligations related to program evaluation.

Grantees will not be permitted to make additional requests for disbursement unless they are current on their quarterly programmatic and expenditure reports and are in compliance with all terms of their Grant Agreement.

Applicants are required to project overall counseling goals in the grant application as well as goals in Targeted Geographic Areas and to minority and low-income populations facing housing instability. Applicants may amend these goals following the grant award based – and only based – on the amount of funds awarded, and new goals will be included in their Grant Agreements. Small variances will be allowed based on goals.

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Each of the Grantee’s disbursements will be evaluated based on allowable variances, and Grantees shall not receive multiple disbursements at one time. Grantees may upload their client-level data to the ORS as frequently as they wish, but not less frequently than quarterly.

If, at NeighborWorks’ sole determination, Grantees do not show substantial progress toward meeting their counseling goals, NeighborWorks reserves the right to recapture or de-obligate funds.

Please see the Disbursement Schedule Example below.

DISBURSEMENT SCHEDULE EXAMPLE

Example: An Intermediary is awarded a grant of $4.37 million. $3.2 million is awarded in Counseling funds, based on a projected 4,000 clients. The Intermediary is awarded $960,000 in Program-Related Support, and $210,000 for Operational Oversight. The disbursement schedule would be as follows:

Disbursement 1 total: $1,865,500: $1,120,000 (35% x $3,200,000) (Counseling) $672,000 (70% x $960,000) (Program-Related Support) $73,500 (35% x $210,000) (Operational Oversight)

Disbursement 2 total: $1,311,000: $960,000 (30% x $3,200,000) (Counseling) $288,000 (30% x $960,000) (Program-Related Support) $63,000 (30% x $210,000) (Operational Oversight)

Disbursement 2 requires that the Intermediary demonstrate it has counseled enough clients to total 35% of its total counseling award ($1,120,000) within the allowable variances as stipulated in the Grant Agreement.

In addition, the Intermediary must complete any quarterly reports that are due before the disbursement can occur and be in compliance with all HSCP terms and Grant Agreement.

Disbursement 3 total: $1,023,000: $960,000 (30% x $3,200,000) (Counseling) $63,000 (30% x $210,000) (Operational Oversight)

Disbursement 3 requires that the Intermediary demonstrate it has counseled enough clients to total 65% of its total counseling award ($2,080,000) AND provide 50% of follow-up outcomes, within the allowable variances as stipulated in the Grant Agreement.

In addition, the Intermediary must complete any quarterly reports that are due before the disbursement can occur and be in compliance with all terms of the program and Grant Agreement.

Final Disbursement: The Intermediary must have counseled enough clients to total 100% of its total counseling award ($3,200,000) AND provided 100% of outcomes. The remaining $170,500 will be disbursed after the final report is completed and the Intermediary has completed its obligations related to program evaluation. The final disbursement consists of 5% of the Intermediary’s Counseling and Operational Oversight funds.

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Other Program Requirements

• Applicant and its Sub-grantees or CCEs must have current certificates in good standing in all states in which it operates. • Applicant and its Sub-grantees or CCEs must be currently authorized to do business in all states where it proposes to provide housing stability counseling services. • In order to keep as many options as possible available to clients, Applicants must not engage in exclusivity agreements with clients seeking housing stability counseling or with other interested parties such as landlords, property management companies, servicers or lenders. Nor shall they otherwise engage in practices which exclude other counseling agencies from working with their clients or their clients’ landlords, property management companies, servicers or lenders, should the client willingly seek assistance from another organization. • SHFA Applicants must have statutory authority to serve the entire state. No more than one SHFA per state will receive an award. • Counseling offices and services must be accessible to persons with disabilities. Grantees must be able to provide a Representations and Warranties Certification for it and all Sub-grantees or CCEs that the buildings in which counseling services are provided are accessible or have a referral list for clients that need accessibility if their building does not provide access, and proactively market and provide services that support remote or technological interest access requests, including TTY • Grantees must have Housing Counselor(s) who are fluent in the language of the clients they serve, or the housing counseling agency must provide a Memorandum of Understanding or other documentation detailing a relationship with services of an interpreter and translation service, or the agency must make a reasonable effort to refer the client to another agency that can meet the client’s needs. • To ensure no financial barriers would prohibit clients from receiving HSCP counseling services, Applicants and their Sub-grantees or CCEs must not charge fees (service fees, membership fees or otherwise) to housing stability counseling clients in exchange for counseling services. Grantees may charge a nominal fee for pulling credit reports if the cost does not deter clients from seeking counseling. • All staff and counselors who provide housing stability counseling under HSCP shall have no conflict(s) of interest due to relationships with landlords, property management companies, servicers, lenders or mortgage companies and/or other entities (including itself) that may stand to benefit from particular counseling outcomes. • Grantees that are using non-HUD-Approved Agencies and/or non-HUD-certified counselors under this Funding Announcement must certify that Sub-grantees or CCEs meet the minimum HUD-approval standards; and that Housing Counselors are actively working towards HUD certification and will monitor them to ensure this is true. • Intermediaries and SHFAs must demonstrate the capacity to serve as an intermediary, including capacity to distribute funds; communicate with Sub-grantees; collect requisite data; and monitor quality, performance, and outcomes of each Sub-grantee. • Each Intermediary, SHFA, and NWO utilizing CCEs is responsible for ensuring their Sub- grantees or CCEs meet counseling standards and must maintain on file in its offices (a) any

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disclosure letters received by Sub-grantees or CCEs that are applying through multiple HSCP Applicants and (b) signed certification forms from Page 1 of the application for each of its Sub- grantees or CCEs. • Intermediaries, SHFAs, and NWOs with CCEs must disburse the majority of Counseling and PRS funds received with each disbursement to their Sub-grantees or CCEs within 30 days of receipt. Requests for exceptions to this provision must be submitted to NeighborWorks in writing at [email protected] for approval. All approved exceptions are at NeighborWorks’ sole discretion. If counselors at Branch Offices are employees of the Applicant corporation, a separate account does not need to be established for each Branch, but the Grantee should be able to demonstrate that the funds were allocated and expended at the Branches indicated in their original application. Otherwise, quarterly reports should clearly demonstrate that the Grantee has disbursed funds in accordance with this provision. • Intermediaries and State HFAs that have received Housing Counseling grants from HUD in the past must be in good standing with HUD. “Not in good standing” is defined as a failure to comply with the laws and regulations that govern the HUD housing counseling program, or the inability of a Grantee to draw down HUD housing counseling grant funds for any reason. • Applicants must demonstrate capacity to obtain, track, and report client-level data electronically. This is essential to avoid payment for duplicate counseling services provided to the same client and to evaluate program effectiveness. Exhibit 3 lists data points that will be collected before each disbursement. Applicants must also have the capacity to collect, aggregate and report overall program and production data electronically. • Grantees must affirm existing internal safeguards and the ability to secure client privacy needs before, during, and after an award is made. The affirmation must: show that the Grantee recognizes that clients to be served by HSCP may require remote access and that they will be accommodated as the Grantee is capable; reflect that information security has been developed, documented and implemented that will satisfy HSCP's stated intent; reflects that Grantees and Sub-grantees or CCEs meet protocols for Personal Identifiable Information (PII) protection for client intake and counseling that align with the Privacy Act; state that all electronic communications with client and any third-party employ the eSign Act and are monitored for security; provide that storage, transmission, access and disclosure of data are done in accordance with the Gramm-Leach-Bliley Act; and state the principles of Fair Information Practice Principles FIPPS are satisfied in regard to transparency, individual participation, purpose specification, data quality and integrity, security, and accountability and auditing. • It is preferable that Applicants currently utilize a Client Management System (CMS). If Applicants are not using a CMS, they must be using a system that can supply required client- level and aggregate data electronically if awarded HSCP funds. • All clients must have equal access to counseling services and must be treated equally in regard to outreach. Grantees, Sub-grantees, CCEs and their counselors must apply the rules of professionalism and treat tenant and non-tenant clients equally. • All counselors providing counseling under HSCP must be HUD-Certified or actively working towards HUD certification. • Grantees with Sub-grantees or CCEs must provide HSCP with a detailed description of how oversight is provided in addition to their signed Grant Agreement.

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• HSCP staff and/or a contracted third-party will conduct client-level and programmatic compliance reviews. Grantees will be required to provide selected HSCP client files and programmatic information for review upon request to ensure compliance with its Grant Agreement. HSCP Audit Requirements • All Applicants must supply their most recent independently audited financial statements (audited financial statements must comport with allowable flexibility recommendations identified as part of the OMB 2020 Compliance Supplement for and M21 for low-risk auditees) or audit in accordance with 2 CFR 200 Uniform Guidance, if applicable, for review (the fiscal year end date of the audit cannot be more than18 months from the date of the application). As defined by NeighborWorks, a complete audit packet includes audited financial statements, single-audit (if applicable), corrective action plan (if applicable), management letter (if issued), organizational responses to management letter (if applicable), and specific clarifying documentation NeighborWorks may request based on the review of the complete audit package.

• Grantees will be required to send NeighborWorks America a complete updated audit package within180 days of the Grantees’ fiscal year end, after receiving grant funds, as well as,180 days after each fiscal year end until the grant is considered closed out.

• Chartered members of the NeighborWorks network already submit their audits through the Organizational Assessment Division and are therefore not required to submit again for this funding opportunity; the most recent audits on file will be reviewed.

• Intermediaries, SHFAs and NWOs are also responsible for ensuring that Sub-grantees and CCEs have completed an independent audit within18 months of the completion of their most recent fiscal year. If a Sub-grantee or CCE has revenues less than $500,000 annually and/or expends less than $750,000 in federal funding per fiscal period, the Sub-grantee or CCE may submit reviewed or compiled financial statements in lieu of independent audited financial statements. It is expected that Applicants are in compliance with the OMB Audit filing guidelines and 2020/2021 Supplement and Memorandum.

• All Applicants must follow the Uniform Grant Guidance applicable to the Office of Management and Budget (OMB) Circulars. Applicants can find additional information regarding the guidance at the OMB website, at: https://ecfr.federalregister.gov/ see PART 200—UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS

• Applicants must affirm they are in good standing with any related American Rescue Plan (ARP) Act of 2021 funding sources exclusive of the HSCP, in order to have any awarded funds disbursed. Funding sources may include those in support of rental, homeless, and foreclosure funding since July 1, 2020. Examples include but are not exclusive to: ARP SEC. 3201. Emergency rental assistance; SEC. 3203. Emergency assistance for rural housing; SEC. 3205. Homelessness assistance and supportive services program; SEC. 3206. Homeowner Assistance Fund; and SEC. 3208. Fair Housing activities. An Applicant “in good standing” does not have active going concerns, suspended, recaptured, terminations due to adverse activity, or any similar action.

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Post-Award Requirements • Client-level data requirements: HSCP Grantees will report client-level data and quarterly reports utilizing the Online Reporting System (ORS), which will be available October 1, 2021. NeighborWorks will provide an Excel template and Data Dictionary which must be followed to successfully report data into the ORS. Data can also be entered manually.

• Quarterly and Final reports must be filed on aggregate activity toward overall goals established under the grant award as will be specified in the Grant Agreement. While disbursements can occur outside of the quarterly report schedule identified in this Funding Announcement, Grantees must be up to date on quarterly reporting in order to obtain the next disbursement. Quarterly reports will include (but not be limited to) progress against aggregate counseling goals and will include a narrative section on overall program activities, successes and challenges encountered in helping clients avoid foreclosure or eviction, and efforts to ensure the affordability of mortgages or rents when clients retain their homes or find new apartments. Final reports will include these items as well as a revenue and expenditure report.

• HSCP requires that all Grantees comply with HUD’s general nondiscrimination and equal opportunity requirements at 24 CFR § 5.105. For additional information on fair housing, please visit the Office of Fair Housing and Equal Opportunity on HUDs website at www.hud.gov that details promoting Fair Housing and Protecting Civil Rights. In accordance with Fair Housing and Civil rights law, NeighborWorks will not permit discrimination by Grantees against clients on the basis of their gender, gender identity, race, color, religion, national origin, ancestry, creed, pregnancy, marital or parental status, familial status, sexual orientation, or physical, mental, emotional or learning disability.

• All Grantees will maintain a separate budget and segregate HSCP funds from other sources of funds. The HSCP grant award must be used to fund Grantees’ housing stability counseling efforts and related expenses. Grantees are responsible for monitoring the expenditures of its Sub-grantees or CCEs to ensure the HSCP funds are being used toward eligible expenses for Counseling and Program-Related Support. In the Final report, all Grantees will report on the expenditure of HSCP funds. Grantees will report in the aggregate for its Sub-grantees and CCEs and should ensure they can furnish documented evidence during the course of HSCP quality control and compliance measures.

• The Final report is due by June 30, 2023. Grantees will not be eligible to receive any subsequent or supplemental funding, should it become available, until they have completed and submitted the Final report.

• Grantees must also comply with a separate evaluation of HSCP activity and client outcomes, which may occur up to three (3) years following the final report.

• Grantees must comply with third-party quality control and compliance measures which may include site visits, file audits, and other measures to ensure compliance with requirements set forth in this Funding Announcement and the Grant Agreement.

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• Grantee must comply with records retention policies in accordance with applicable law. Grantee must establish and comply with the following:

o Financial records, supporting documentation, statistical records, and all records pertinent to the grant shall be retained for a period of three (3) years from the date of submission of the Final report. The only exceptions are the following:

o If any litigation, claim, or audit is started before expiration of the three (3) year period, the records shall be retained until the litigation, claims or audit findings involving the records have been resolved and final action is taken.

o Records for real property and equipment acquired with the grant funds shall be retained for three (3) years after final disposition. Notwithstanding the foregoing, or any other provision in the Funding Announcement and Grant Agreement, NeighborWorks’ and its authorized representatives’, agents’ and third-party contractors’ rights to site, document and personnel access for evaluation purposes are not limited to the required retention period but shall last as long as records are retained.

o HSCP Grantees must have policies and procedures in place to ensure HSCP records are not permanently destroyed as a result of a natural or man-made disaster for itself and any Sub-grantees or CCEs.

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Exhibit 1: HSCP Targeting Methodology

The authorizing legislation stipulates that a minimum of 40 percent of funds shall be provided to counseling organizations that: 1. target housing counseling services to minority and low-income populations facing housing instability; or 2. provide housing counseling services in neighborhoods having high concentrations of minority and low-income populations.

To satisfy the statutory requirements, NeighborWorks will: 1. require that HSCP clients self-certify that they are currently facing housing instability; 2. request Applicants provide a projection of the percentage of low-income and minority people they anticipate serving; and, 3. request Applicants identify “Targeted Geographic Areas” which will be served, and the number of clients in each Targeted Geographic Area.

NeighborWorks has defined counties having high percentage of cost burdened households (75th percentile or higher) or high social vulnerability (75th percentile or higher) as Targeted Geographic Areas. Grantees that will provide housing stability counseling in the defined Targeted Geographic Areas will be prioritized for funding, however, all counties in the United States and all U.S Territories are eligible for HSCP funding. Note that counties in U.S territories are included for prioritization in their entirety.

NeighborWorks will monitor client level reporting to include zip code, race and ethnicity and low- income status, among others to ensure the program is compliant with the legislation.

Methodology for determination of HSCP’s Targeted Geographic Areas • Using U.S. Census Bureau data on owner-occupied and renter households with cost burden (defined as those spending 30% or more of income on housing), we calculated the percentage of households experiencing cost burden by area. We then calculated Cost Burden Percentiles by ranking every area in the United States against one another using percentile values ranging from 0 to 1, with higher values indicating greater proportion of households with housing cost burden. • Using the U.S. Center for Disease Control’s Social Vulnerability Index (SVI), we ranked counties based on other relevant factors. The SVI ranks counties on 15 social factors, including unemployment, minority status, and disability; and further groups them into four related themes, so that each area receives a ranking for each Census variable, for each of the four related themes, as well as for an overall ranking. We use the overall ranking that incorporates all 15 social factors using percentile values ranging from 0 to 1, with higher values indicating greater vulnerability. • To identify counties in the United States that will be prioritized for HSCP funding, we defined a Targeted Geographic Area as any area that is in the 75th percentile or higher either for cost burden OR for social vulnerability. • As a result of this methodology, a total of 1,275 counties in the United States (41% of all counties) are being prioritized for HSCP funding. U.S. Territories were excluded from the analysis due to data unavailability and are included in the Target Geographic Areas in their entirety.

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Sources 1. Tenure by Housing Costs as a Percentage of Income in the Past 12 months, Table ID B25106; U.S. Census Bureau, 2015-2019 American Community Survey 5-Year Estimates and Centers for Disease Control and Prevention/Agency for Toxic Substances and Disease Registry/Geospatial Research, Analysis, and Services Program 2. CDC/ATSDR Social Vulnerability Index 2018 Database. US. More information can be found at: https://svi.cdc.gov/Documents/Data/2018_SVI_Data/SVI2018Documentation.pdf

HSCP TARGETED GEOGRAPHIC AREAS

Alabama Barbour County DeKalb County Mobile County Bullock County Escambia County Montgomery County Butler County Franklin County Perry County Calhoun County Geneva County Pickens County Chilton County Greene County Pike County Choctaw County Hale County Russell County Clarke County Jefferson County Sumter County Conecuh County Lee County Talladega County Covington County Lowndes County Tallapoosa County Dale County Macon County Tuscaloosa County Dallas County Marengo County Wilcox County

Alaska Anchorage Municipality Kusilvak Census Area Northwest Arctic Borough Prince of Wales-Hyder Census Bethel Census Area Lake and Peninsula Borough Area Dillingham Census Area Matanuska-Susitna Borough Sitka City and Borough Fairbanks North Star Borough Nome Census Area Yukon-Koyukuk Census Area Ketchikan Gateway Borough American Samoa (all areas)

Arizona Apache County La Paz County Pinal County Cochise County Maricopa County Santa Cruz County Coconino County Mohave County Yavapai County Gila County Navajo County Yuma County Graham County Pima County

Arkansas Arkansas County Hempstead County Nevada County Ashley County Hot Spring County Ouachita County Bradley County Howard County Phillips County Chicot County Independence County Poinsett County

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Clark County Jackson County Polk County Columbia County Jefferson County Pope County Conway County Johnson County Pulaski County Craighead County Lafayette County St. Francis County Crittenden County Lee County Scott County Dallas County Lincoln County Sebastian County Desha County Logan County Sevier County Drew County Miller County Union County Faulkner County Mississippi County Woodruff County Garland County Monroe County Yell County

California Alameda County Marin County San Luis Obispo County Alpine County Mariposa County San Mateo County Amador County Mendocino County Santa Barbara County Butte County Merced County Santa Clara County Calaveras County Modoc County Santa Cruz County Colusa County Mono County Shasta County Contra Costa County Monterey County Sierra County Del Norte County Napa County Siskiyou County El Dorado County Nevada County Solano County Fresno County Orange County Sonoma County Glenn County Placer County Stanislaus County Humboldt County Plumas County Sutter County Imperial County Riverside County Tehama County Inyo County Sacramento County Trinity County Kern County San Benito County Tulare County Kings County San Bernardino County Tuolumne County Lake County San Diego County Ventura County Los Angeles County San Francisco County Yolo County Madera County San Joaquin County Yuba County

Colorado Adams County Eagle County Montrose County Alamosa County Elbert County Morgan County Arapahoe County El Paso County Otero County Archuleta County Garfield County Ouray County Bent County Gilpin County Pitkin County Boulder County Grand County Prowers County Chaffee County Gunnison County Pueblo County Clear Creek County Jefferson County Rio Grande County Conejos County Lake County Routt County Costilla County La Plata County Saguache County Crowley County Larimer County San Miguel County Custer County Las Animas County Summit County Delta County Mesa County Teller County

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Denver County Moffat County Weld County

Connecticut Fairfield County Middlesex County Tolland County Hartford County New Haven County Windham County Litchfield County New London County

Delaware Kent County New Castle County

District of Columbia District of Columbia

Florida Alachua County Hardee County Okaloosa County Bay County Hendry County Okeechobee County Bradford County Highlands County Orange County Brevard County Hillsborough County Osceola County Broward County Holmes County Palm Beach County Calhoun County Indian River County Pasco County Charlotte County Jackson County Pinellas County Collier County Lafayette County Polk County Columbia County Lake County Putnam County DeSoto County Lee County St. Lucie County Dixie County Leon County Sarasota County Duval County Levy County Seminole County Escambia County Liberty County Suwannee County Flagler County Madison County Taylor County Franklin County Manatee County Union County Gadsden County Marion County Volusia County Gilchrist County Martin County Walton County Glades County Miami-Dade County Washington County Hamilton County Monroe County

Georgia Appling County Emanuel County Rabun County Atkinson County Evans County Randolph County Bacon County Floyd County Richmond County Baker County Franklin County Rockdale County Baldwin County Fulton County Schley County Bartow County Glynn County Screven County Ben Hill County Gordon County Seminole County Berrien County Grady County Spalding County Bibb County Greene County Stephens County Brooks County Gwinnett County Stewart County Bryan County Hancock County Sumter County

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Bulloch County Hart County Talbot County Burke County Irwin County Taliaferro County Butts County Jeff Davis County Tattnall County Calhoun County Jefferson County Taylor County Camden County Jenkins County Telfair County Candler County Johnson County Terrell County Carroll County Lamar County Thomas County Charlton County Lanier County Tift County Chatham County Laurens County Toombs County Chattahoochee County Liberty County Treutlen County Chattooga County Lincoln County Troup County Clarke County Long County Turner County Clay County Lowndes County Twiggs County Clayton County McDuffie County Upson County Clinch County McIntosh County Walton County Coffee County Macon County Ware County Colquitt County Marion County Warren County Cook County Meriwether County Washington County Crisp County Miller County Wayne County Decatur County Mitchell County Webster County DeKalb County Montgomery County Wheeler County Dodge County Muscogee County Whitfield County Dooly County Newton County Wilcox County Dougherty County Peach County Wilkes County Douglas County Polk County Wilkinson County Early County Pulaski County Elbert County Quitman County

Guam (all areas) Hawaii Hawaii County Kauai County Maui County Honolulu County

Idaho Ada County Clark County Madison County Blaine County Elmore County Owyhee County Bonner County Gem County Shoshone County Camas County Kootenai County Valley County Canyon County Latah County Washington County

Illinois Alexander County Jefferson County Massac County Champaign County Kane County St. Clair County Coles County Kankakee County Saline County Cook County Lake County Vermilion County

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DeKalb County Lawrence County Will County DuPage County McDonough County Winnebago County Jackson County McHenry County

Indiana Delaware County Monroe County Vanderburgh County Elkhart County Tippecanoe County Vigo County Marion County

Iowa Crawford County Johnson County Story County

Kansas Crawford County Geary County Riley County Douglas County Linn County Seward County Finney County Montgomery County Wyandotte County Ford County

Kentucky Barren County Graves County Montgomery County Bell County Harlan County Morgan County Breathitt County Hart County Nicholas County Butler County Jefferson County Owsley County Calloway County Johnson County Perry County Carroll County Knott County Pike County Carter County Knox County Powell County Casey County Laurel County Pulaski County Christian County Lawrence County Rockcastle County Clay County Lee County Rowan County Clinton County Leslie County Russell County Estill County Letcher County Todd County Fayette County McCreary County Webster County Fleming County Magoffin County Whitley County Floyd County Marion County Wolfe County Fulton County Martin County

Louisiana Acadia Parish Iberia Parish Sabine Parish Allen Parish Iberville Parish St. Bernard Parish Assumption Parish Jackson Parish St. Helena Parish Avoyelles Parish Jefferson Parish St. Landry Parish Bienville Parish Jefferson Davis Parish St. Martin Parish Bossier Parish Lafourche Parish St. Mary Parish Caddo Parish LaSalle Parish Tangipahoa Parish Caldwell Parish Lincoln Parish Tensas Parish Catahoula Parish Madison Parish Terrebonne Parish

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Claiborne Parish Morehouse Parish Union Parish Concordia Parish Natchitoches Parish Vermilion Parish De Soto Parish Orleans Parish Washington Parish East Baton Rouge Parish Ouachita Parish Webster Parish East Carroll Parish Pointe Coupee Parish West Baton Rouge Parish East Feliciana Parish Rapides Parish Winn Parish Evangeline Parish Red River Parish Franklin Parish Richland Parish

Maine Androscoggin County Lincoln County Sagadahoc County Cumberland County Oxford County York County Knox County Piscataquis County

Maryland Anne Arundel County Dorchester County Somerset County Baltimore County Kent County Talbot County Caroline County Montgomery County Wicomico County Cecil County Prince George's County Worcester County Charles County Queen Anne's County Baltimore City

Massachusetts Barnstable County Franklin County Norfolk County Berkshire County Hampden County Plymouth County Bristol County Hampshire County Suffolk County Dukes County Middlesex County Worcester County Essex County Nantucket County

Michigan Calhoun County Ingham County Ogemaw County Clare County Isabella County Washtenaw County Genesee County Lake County Wayne County Houghton County Oceana County

Minnesota Aitkin County Clearwater County Nobles County Beltrami County Hennepin County Pine County Blue Earth County Mahnomen County Ramsey County Clay County Mille Lacs County

Mississippi Adams County Jefferson County Prentiss County Amite County Jefferson Davis County Quitman County Attala County Jones County Scott County Bolivar County Kemper County Sharkey County Calhoun County Lafayette County Simpson County

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Chickasaw County Lauderdale County Sunflower County Choctaw County Leake County Tallahatchie County Claiborne County Lee County Tate County Clay County Leflore County Tippah County Coahoma County Lincoln County Tunica County Copiah County Lowndes County Union County Covington County Marion County Walthall County Forrest County Montgomery County Warren County Grenada County Neshoba County Washington County Harrison County Newton County Wayne County Hinds County Noxubee County Wilkinson County Holmes County Oktibbeha County Winston County Humphreys County Panola County Yazoo County Issaquena County Pike County Jasper County Pontotoc County

Missouri Adair County Lawrence County Scott County Boone County McDonald County Taney County Butler County Mississippi County Texas County Crawford County New Madrid County Washington County Dunklin County Oregon County Wayne County Greene County Pemiscot County Wright County Iron County Pettis County St. Louis City Jackson County Saline County

Montana Beaverhead County Glacier County Pondera County Big Horn County Lake County Ravalli County Blaine County Lincoln County Roosevelt County Flathead County Missoula County Sanders County Gallatin County Park County Yellowstone County

Nebraska Dakota County Douglas County Thurston County Dawson County Scotts Bluff County

Nevada Clark County Mineral County Washoe County Douglas County Pershing County Carson City Lander County Storey County

New Hampshire Belknap County Grafton County Rockingham County Carroll County Hillsborough County Strafford County Cheshire County Merrimack County Sullivan County

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New Jersey Atlantic County Gloucester County Ocean County Bergen County Hudson County Passaic County Burlington County Hunterdon County Salem County Camden County Mercer County Somerset County Cape May County Middlesex County Sussex County Cumberland County Monmouth County Union County Essex County Morris County Warren County

New Mexico Bernalillo County Hidalgo County San Juan County Chaves County Lea County San Miguel County Cibola County Luna County Santa Fe County Colfax County McKinley County Sierra County Curry County Mora County Socorro County Doña Ana County Otero County Taos County Grant County Quay County Torrance County Guadalupe County Roosevelt County Valencia County

New York Albany County Monroe County Richmond County Bronx County Montgomery County Rockland County Broome County Nassau County Schenectady County Columbia County New York County Suffolk County Dutchess County Orange County Sullivan County Erie County Orleans County Tompkins County Greene County Otsego County Ulster County Jefferson County Putnam County Warren County Kings County Queens County Westchester County

North Carolina Alamance County Greene County Pender County Anson County Guilford County Perquimans County Beaufort County Halifax County Person County Bertie County Harnett County Pitt County Bladen County Hertford County Richmond County Brunswick County Hoke County Robeson County Buncombe County Hyde County Rockingham County Burke County Jones County Rowan County Camden County Lee County Rutherford County Caswell County Lenoir County Sampson County Chowan County McDowell County Scotland County Cleveland County Martin County Swain County Columbus County Mecklenburg County Tyrrell County Craven County Montgomery County Vance County

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Cumberland County Nash County Warren County Dare County New Hanover County Washington County Duplin County Northampton County Watauga County Durham County Onslow County Wayne County Edgecombe County Orange County Wilson County Forsyth County Pasquotank County

North Dakota Benson County Rolette County Sioux County Grand Forks County

Northern Mariana Islands (all areas) Ohio Adams County Franklin County Montgomery County Ashtabula County Hamilton County Pike County Athens County Jackson County Portage County Cuyahoga County Lucas County Scioto County

Oklahoma Adair County Haskell County Oklahoma County Atoka County Hughes County Okmulgee County Bryan County Jackson County Ottawa County Caddo County Jefferson County Payne County Carter County Johnston County Pittsburg County Cherokee County Kay County Pottawatomie County Choctaw County Latimer County Pushmataha County Coal County Le Flore County Seminole County Comanche County McCurtain County Sequoyah County Craig County McIntosh County Texas County Custer County Marshall County Tillman County Delaware County Mayes County Tulsa County Greer County Muskogee County Harmon County Okfuskee County

Oregon Benton County Jackson County Morrow County Clackamas County Jefferson County Multnomah County Clatsop County Josephine County Polk County Columbia County Klamath County Tillamook County Coos County Lake County Umatilla County Crook County Lane County Wasco County Curry County Lincoln County Washington County Deschutes County Linn County Wheeler County Douglas County Malheur County Yamhill County Grant County Marion County

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Pennsylvania Berks County Lackawanna County Montgomery County Bucks County Lancaster County Northampton County Centre County Lehigh County Philadelphia County Dauphin County Lycoming County Pike County Delaware County Monroe County

Puerto Rico (all areas) Rhode Island Bristol County Newport County Washington County Kent County Providence County

South Carolina Abbeville County Dillon County Lee County Allendale County Dorchester County Marion County Bamberg County Edgefield County Marlboro County Barnwell County Fairfield County Newberry County Beaufort County Florence County Orangeburg County Charleston County Georgetown County Richland County Cherokee County Greenwood County Saluda County Chesterfield County Hampton County Spartanburg County Clarendon County Horry County Sumter County Colleton County Jasper County Union County Darlington County Laurens County Williamsburg County

South Dakota Bennett County Custer County Oglala Lakota County Buffalo County Dewey County Pennington County Butte County Jackson County Todd County Clay County Lawrence County Ziebach County Corson County Mellette County

Tennessee Bedford County Hardeman County Rhea County Bledsoe County Haywood County Scott County Crockett County Lake County Shelby County Davidson County Lauderdale County Trousdale County Dyer County Lawrence County Unicoi County Grundy County Madison County Warren County Hamblen County Montgomery County Wayne County Hamilton County Obion County Hancock County Putnam County

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Texas Anderson County Galveston County Mills County Angelina County Gonzales County Nacogdoches County Aransas County Gray County Navarro County Atascosa County Gregg County Nolan County Bailey County Grimes County Nueces County Bee County Hale County Palo Pinto County Bell County Hall County Parmer County Bexar County Hansford County Pecos County Bowie County Harris County Polk County Brazos County Haskell County Potter County Brooks County Hays County Presidio County Caldwell County Hidalgo County Reeves County Calhoun County Hill County Refugio County Cameron County Hockley County Robertson County Camp County Houston County Rusk County Cass County Howard County San Augustine County Castro County Hudspeth County San Patricio County Cherokee County Hunt County Shelby County Childress County Jasper County Smith County Cochran County Jefferson County Starr County Collin County Jim Hogg County Stephens County Collingsworth County Jim Wells County Swisher County Coryell County Karnes County Tarrant County Cottle County Kaufman County Taylor County Crosby County Kinney County Terry County Culberson County Kleberg County Titus County Dallas County Knox County Travis County Dawson County Lamar County Trinity County Deaf Smith County Lamb County Tyler County Denton County Lampasas County Uvalde County DeWitt County La Salle County Val Verde County Dickens County Liberty County Victoria County Dimmit County Limestone County Walker County Duval County Loving County Waller County Eastland County Lubbock County Webb County Ector County Lynn County Wharton County El Paso County McLennan County Wichita County Erath County McMullen County Wilbarger County Falls County Madison County Willacy County Floyd County Matagorda County Zapata County Freestone County Maverick County Zavala County Frio County Milam County

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Utah Cache County San Juan County Washington County

Vermont Addison County Franklin County Rutland County Bennington County Grand Isle County Washington County Caledonia County Lamoille County Windham County Chittenden County Orange County Windsor County Essex County Orleans County

Virgin Islands (all areas)

Virginia Accomack County Nottoway County Hampton City Arlington County Prince Edward County Harrisonburg City Brunswick County Prince William County Hopewell City Buchanan County Richmond County Lexington City Buckingham County Shenandoah County Lynchburg City Caroline County Smyth County Manassas City Charles City County Sussex County Manassas Park City Clarke County Westmoreland County Martinsville City Cumberland County Wise County Newport News City Dickenson County Alexandria City Norfolk City Dinwiddie County Bristol City Norton City Essex County Buena Vista City Petersburg City Fairfax County Charlottesville City Portsmouth City Greensville County Chesapeake City Radford City Henrico County Colonial Heights City Richmond City Henry County Danville City Roanoke City Lee County Emporia City Staunton City Lunenburg County Fairfax City Suffolk City Madison County Falls Church City Virginia Beach City Mecklenburg County Franklin City Waynesboro City Middlesex County Fredericksburg City Williamsburg City Montgomery County Galax City Winchester City

Washington Adams County Jefferson County Skagit County Clallam County King County Snohomish County Clark County Kitsap County Spokane County Cowlitz County Kittitas County Thurston County Douglas County Klickitat County Wahkiakum County Ferry County Lewis County Walla Walla County Franklin County Mason County Whatcom County Grant County Okanogan County Whitman County

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Grays Harbor County Pierce County Yakima County Island County San Juan County

West Virginia Cabell County McDowell County Monongalia County Fayette County Mercer County Raleigh County Gilmer County Mingo County Summers County

Wisconsin Ashland County Menominee County Vilas County Dane County Milwaukee County Walworth County Kenosha County Racine County

Wyoming Albany County Niobrara County

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Exhibit 2: HSCP Minimum HUD Approval Standards

HSCP Applicants must be HUD-Approved Counseling Agencies or certify that they meet the minimum standards, as identified by HSCP for HUD approval. Grantees will be required to maintain HUD approval or the certification of meeting the HSCP minimum HUD approval standards throughout the HSCP performance period and must immediately notify HSCP of any changes. Failure to do so may result in de-obligation and/or recapture of HSCP grant funds.

HSCP Minimum standards for HUD approval. All boxes must be checked.

☐ 1. Agency is in compliance with state and local requirements to do business in the communities served. ☐ 2. Agency does NOT have any unresolved fair housing or civil rights violations. ☐ 3. Agency can provide Conflict of Interest procedures and explain any conflicts of Interest. ☐ 4. Agency staff working in the housing counseling program are NOT: a. Suspended or disbarred from participating in Federal program b. Indicted or convicted for a criminal offense that reflects responsibility, integrity, or ability of the agency to participate in housing counseling activities c. Subject to any unresolved findings in a Federal investigation Or any government audit or investigation ☐ 5. Agency has NOT violated the following election laws a. Been convicted of a violation under Federal law relating to an election for Federal office, OR b. One or more individuals employed by your agency in a permanent or temporary capacity; contracted or retained by your agency; or acting on behalf of, or with the express or apparent authority of, your agency been convicted of a violation under Federal law relating to an election for Federal office ☐ 6. Agency has administered a housing counseling program meeting HUD requirements. defined in for the last 12 months (e.g., meets the HUD Housing Counseling Program regulations in 24 CFR 214 and in Chapter 2, 2-2 and Chapter 3 of Handbook 7610.1 Rev 5). ☐ 7. Agency has operated a housing counseling program for at least one year in the same geographic area(s) to be proposed in the application. ☐ 8. Agency has staff with the appropriate language skills for their housing counseling clients or has an adequate referral process for persons with limited English proficiency. ☐ 9. Agency has alternative formats and reasonable accommodations for those with disabilities. ☐ 10. Agency has a process and procedures for privacy, reporting and recordkeeping.

Applicant will certify to all of the above on behalf of the Applicant, sub-grantee and/or CCE at time of application. Grantees are required to maintain a signed copy for itself and its Sub-grantees and CCEs HSPC program monitoring and compliance.

I ______certify that ______(Agency Name) certify that the above statements are true and understand should my agency fall out of compliance with any of the above listed items and/or our agency as a Grantee do not have a signed copy for our agency and our Sub-grantees and CCEs, if applicable we may be removed as a Grantee from HSCP and may be subject to de-obligation and/or recapture.

Signature: Date:

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Exhibit 3: Draft HSCP Client Level Data Reporting Requirements

HSCP Grantees will report client-level data and quarterly reports utilizing the NeighborWorks Online Reporting System (ORS), which will be available October 1, 2021. NeighborWorks will provide an Excel template and Data Dictionary which must be followed to successfully report data into the ORS. Data can also be entered manually.

The following are draft data points to be collected for each client and are subject to change prior to the time of grant award. If, upon implementation of the HSCP, it is realized that certain data points are problematic or not able to be transferred in the manner they were designed by a significant number of Grantees, we will notify all Grantees and expect such details to be noted in client files rather than submitted electronically.

HSCP Data Points

Data Description Values Required? Point 1 Grantee ID Grantee identifier Yes

2 Sub-grantee ID Sub grantee identifier (defined by Yes Grantee)

3 Client Unique Identifier Client's ID (defined by Grantee) Yes

4 Counseling Level Reported L1, L2, Follow-up Yes

5 Counseling Intake Date Intake date must be on or after Yes ratified grant agreement date

6 Counseling Mode Phone Yes Face to face Video conference Group Other

7 Ethnicity Hispanic Yes Not Hispanic Chose not to respond

8 Race American Indian /Alaskan Native Yes Asian Black or African American Native Hawaiian or Other Pacific Islander White More than one race Chose not to respond

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9 Limited English Proficiency Limited English Proficient Yes Not Limited English Proficient Chose not to respond

10 Client Language Spoken Arabic Yes Cambodian Cantonese Chinese Mandarin Czech French Hindi Indonesian Korean Polish Portuguese Russian Swahili Turkish Vietnamese English Spanish Farsi Ukrainian ASL Hmong Creole Other German Italian

11 Client Disabled Yes/No/Unknown Yes

12 Gender Female Yes Male Gender Non-Conforming Chose not to respond

13 Head of Household Single adult Yes Female‐headed single parent household Male‐headed single parent household Married without dependents Married with dependents Two or more unrelated adults Other

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14 Household Family Income at Intake Client Household Gross Monthly Yes Income

15 Household Gross Income Category (% of AMI) Less than 30% of Area Median Income Yes (AMI) 30 – 49% of AMI 50 – 79% of AMI 80 ‐ 100% of AMI Greater than 100% AMI Choose not to respond

16 House Number and Street Name House # and street name property Yes

17 Apt. or Unit # Apartment or Unit # Yes

18 City The actual city location of the property Yes

19 State Two-digit state (or U.S. territory) code Yes of property

20 Zip Five-digit ZIP code of property Yes

21 Reason(s) Housing Instability Eviction Yes Default Foreclosure Loss of income Homelessness

22 Does household spend more than 30% of gross Yes/No Yes income on housing (rent or mortgage)?

23 Credit Score Obtained Yes/No Yes

24 Credit Score (if no score enter 999) FICO Score Conditional

25 Source of Credit Report Equifax Experian TransUnion Tri-Merge Other

26 Client referred to and/or assisted with access to Emergency Rental Assistance Yes financial resources for housing stability Housing Assistance Fund State/Local Resources Private Other N/A

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27 Did client enter into forbearance agreement Yes Yes during COVID-19 pandemic? No Unknown

28 Client Mortgage Loan Type FHA Yes VA USDA GSEs Private Other

29 Homeowners: PITI Total of all loans and escrows: principal, Yes interest, taxes, and insurance(s) paid by client (at intake and at follow-up, including MI/HOA if applicable)

30 Client Mortgage Delinquency Current/not in default Yes 30‐60 days late 61‐90 days late 91‐120 days late 121+ days late

31 Did client benefit from eviction moratoria Yes Yes during COVID-19 pandemic? No Unknown

32 Monthly Rent Amount Monthly arrangement (excluding Yes utilities)

33 Total Amount of Rent Arrears All back rent, including any fees Yes

34 Total Number of Months’ Rent Due Number of months with partial or no Yes payment

35 Counseling Outcome: Homeowners In moratorium or action pending Yes Referred client to servicer with action plan and no further counseling activity Currently in negotiation with servicer Brought mortgage current (w/o rescue funds) Brought mortgage current with rescue funds (private/public) Arrearage cancelled or waived Refinanced Forbearance Repayment Plan Modification

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Partial claim Deed-in-Lieu Short sale Foreclosed Homeowner(s) sold property (not short sale) Bankruptcy Transition to new rental Counseled and gained access to non- housing resources: Social or legal services, public benefits, Social Security or Medicaid Counseled and Occupied Emergency Shelter, Transitional Housing, Permanent Housing with or without rental assistance Withdrew from counseling

36 Counseling Outcomes: Renters Repayment plan in compliance Yes Initiated repayment plan Repayment plan breached Executed a lease renewal Received Rent Forgiveness Received Emergency Rental Assistance Avoided a legal eviction Counseled and gained access to non- housing resources: Social or legal services, public benefits, Social Security or Medicaid Counseled and Occupied Emergency Shelter, Transitional Housing, Permanent Housing with or without rental assistance Referred to bankruptcy Withdrew from counseling Currently in negotiation with landlord; outcome unknown Referred client to landlord with action plan and no further counseling activity; outcome unknown Eviction put on hold or in moratorium; final outcome unknown Brought rent current with rescue funds (private/public) Brought rent current (without rescue funds) Rent burden = or < 30% Rent burden between 41-50% Rent burden = or > 50% Renter initiated move-out Counseled and transition to new rental Counseled on debt management (including Payday and Vehicle Title

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Loans) or referred to debt management agency Ending counseling after level II-- outcome unknown

37 Counseling Outcome Date May align to log notation: file Yes termination

Not required: The HSCP requests that you submit this information if it is known. The Outcome data, mode of counseling, and credit score information is particularly crucial to the evaluation of this program. Please make a point to report these data as much as possible. Note: For counseling outcomes, if you've heard back from the servicer that they have agreed upon an outcome, enter that outcome even if official bank documentation has not been received.

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Exhibit 4: HSCP Award Disbursement Requirements

1. Draw 1 (Draw 1 = 35% of Counseling; 70% of PRS; 35% of OO)

Released upon NeighborWorks’ receipt of fully executed Grant Agreements and required start-up documentation.

2. Disbursement 2 (Disbursement 2 = 30% of Counseling; 30% of PRS; 30% of OO) Total disbursed to Grantee at this point is 65% of Counseling; 100% of PRS; 65% of OO.

Released when enough clients have been counseled to total 35% of the Counseling Award dollar amount and: A. Grantee has no significant compliance findings B. Grantee is within allowable variances for Targeted Geographic Areas and service to minority and low-income populations facing housing instability

3. Disbursement (Disbursement 3 = 30% of Counseling; 30% of OO) Total disbursed to Grantee at this point is 95% of Counseling; 100% of PRS; 95% of OO.

Released when enough clients have been counseled to total 65% of the Counseling Award dollar amount3 and: A. Grantee has no significant compliance findings B. Grantee is within allowable variances for Targeted Geographic Areas and service to minority and low-income populations facing housing instability

4. Disbursement 4 (Disbursement 4 = 5% of counseling; 5% of OO) Total disbursed to Grantee is 100% of Counseling; 100% of PRS; 100% of OO.

Released when: A. Grantee has counseled enough borrowers to fully spend down 100% of the dollar amount awarded to it in Counseling Funds3. Note the HSCP will allow some variance for L1 clients that do not see L2 services after follow-up. If less L1 clients are reported than funds requested in the application, this will be calculated and applied at Disbursement 4 and will reduce the dollar amount and/or units of counseling needing to be achieved before releasing Disbursement 4. B. Grantee has no significant compliance findings C. Grantee has demonstrated progress towards targeted geographic areas and/or to low-income or minority populations facing housing instability as stated in its grant agreement. If the Grantee falls below projections and is not reporting 40% of their targeted geographic areas and/or to low-income or minority populations facing housing instability, they be subject to de-obligation and/or recapture. D. Grantee has completed its Final HSCP Programmatic Report

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