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An Essential Guide to HAF Program Closeout

Author: Reginald H. Givens, Homeownership Policy Lead, Ambipar Response | Witt O'Brien's

As the Department of the Treasury’s Homeowner Assistance Fund (HAF) approaches its September 30, 2026 Period of Performance (POP) deadline, the urgency for funding recipients to prepare for program closeout and ensuing audits intensifies. Initiated to provide a lifeline to homeowners facing mortgage challenges, HAF’s broader objectives hinge not only on the allocation of funds but also on the strategic winding down and compliance scrutiny of its programs. With the program’s closeout on the horizon, the challenge shifts to a proactive closure strategy that ensures compliance and positions programs for successful audits, encapsulating a journey filled with potential pitfalls and strategic maneuvers for success.

Preparation Avoids Peril: The Stakes of Inadequate Closeout Planning

Inadequate preparation for program closeout introduces a spectrum of risks—including financial penalties, disqualification from future funding, and erosion of trust among stakeholders. Such oversight compromises the foundational goal of supporting homeowners, underlining the gravity of methodical closeout and documentation practices. Moreover, the attrition of staff and dilution of institutional knowledge in the twilight of the program’s lifecycle accentuate the vulnerability to audit discrepancies, spotlighting the paramount importance of continuity in expertise and documentation integrity.

Blueprint for Success: Strategic Foundations for Program Closeout

Effective closeout preparation must begin at the program’s inception, incorporating systematic maintenance of critical documentation and policies to facilitate smoother audits. This forward-thinking approach not only streamlines the audit process but also ensures compliance with regulations regarding the management of program income post-closeout.

Strategic fund management extends the program’s legacy, leveraging residual funds to bolster ongoing or future initiatives. To effectively manage program funds and avoid issues with unspent revenue, it’s crucial to strategically plan your program funding. Any excess income generated during the performance period must be returned to the Treasury unless it’s reinvested in the program. Income earned after this period can be used to support legacy efforts or enhance current programs by adding or modifying components.

This meticulous planning for the endgame ensures that the program’s impact resonates beyond its operational lifespan, embodying a commitment to sustainability and long-term success.

The Ripple Effect of Readiness: Beyond Compliance to Operational Excellence

Audit-readiness transcends regulatory compliance, enabling operational efficiencies and building resilience against the unpredictability of audits. Being prepared bolsters stakeholder confidence by fortifying the program’s structural integrity and helping ensure that the financial lifeline to those in need remains sustainable. Furthermore, strategic navigation of program income and adherence to audit protocols engrains a standard of excellence into the operational fabric of the program, enhancing its efficacy and impact.

Harnessing Expertise: A Lighthouse in the Regulatory Storm

Navigating the complexities of HAF program management and the rigor of achieving audit preparedness requires specialized expertise in guiding programs through the labyrinth of regulatory requirements. Engaging with experts familiar with federal funding compliance can offer invaluable insights and strategies to avoid common pitfalls, ensuring programs not only meet but exceed audit expectations. These types of partnerships have proven instrumental in ensuring regulatory compliance and in amplifying the program’s reach and impact through strategic program income management and effective planning for post-closeout endeavors.

Heeding the Call for Preparedness

Although the HAF closeout deadline is still months away, complacency is the enemy of program success. The notion that there is ample time to get your “house” in order masks the intricate and time-consuming nature of closeout and audit preparedness. Funding recipients, and subrecipients, should take immediate, proactive steps toward readiness. A smart first step is to critically evaluate your current state of preparedness, identify areas for improvement, and engage with expert partners to fortify your compliance and readiness posture.

A Pledge to Excellence and Impact

The journey toward the closeout of HAF-funded programs can be a testament to your jurisdiction’s overarching mission to provide quality, affordable housing in your community. Being audit-ready encapsulates a strategic, forward-looking approach that ensures programs not only comply with regulatory mandates but also maximize their impact and legacy. As the countdown to the closeout deadline continues, embracing a preparedness mindset and engaging with the wealth of available expertise will be keystones of your success. In this critical period, let the collective commitment to the wellbeing of people in need and the efficacy of your assistance programs guide your path forward—ensuring that the HAF initiative realizes its full potential in service to those it seeks to uplift.

  • Begin planning for closeout at the inception of your program.

  • Review prior audit results. This includes other programs and any findings on these programs that could be useful as you plan for closeout. This would include at your program design phase.      

  • Have policies and procedures in place to ensure audit-readiness and to reflect program goals and objectives.

  • Follow essential documentation and recordkeeping practices—including all applications, exceptions, and appeals.

  • Anticipate and prepare for potential questions from auditors.

  • File all Quality Control (QC) data—including processes, findings, and actions taken.

  • Determine the process for presenting the files for audit.

  • Pull and export all case files; ensure file dispositions are final and case documentation aligns.

  • Review Treasury guidance for closeout and ensure proper preparation (have the documentation or a process in place for each component). For instance, your inventory of equipment purchased on the project.

  • Engage stakeholders and maintain open communications channels—particularly with subrecipients, community-based organizations, and homeowners.

  • Develop the process for resolving incomplete HAF Common Data File (CDF) exchanges.

  • If assistance was delivered as anything other than a grant, ensure you establish an appropriate monitoring process.

  • Prepare for future use of program income, as applicable.


Reginald (Reg) serves as a Director and Homeowner Policy Lead in Witt O’Brien’s Community Services practice. He is a Hardest Hit Fund (HHF) program expert with more than 20 years’ experience in the residential mortgage and lending business providing housing assistance through acquisition and preservation.

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