Notice of Funding Opportunity (NOFO) – Housing Counseling Grant Program

U.S. Department of Housing and Urban Development
Office of Housing
Notice of Funding Opportunity (NOFO) for the Department's Fiscal Year 2021 Comprehensive
Housing Counseling Grant Program
FR-6500-N-33
10/14/2021

Table of Contents
Overview ...................................................................................................................................... 3
I. FUNDING OPPORTUNITY DESCRIPTION ......................................................................... 3
A. Program Description. .............................................................................................................. 3
B. Authority. ............................................................................................................................... 9
II. Award Information. ................................................................................................................. 9
A. Available Funds ....................................................................................................................... 9
B. Number of Awards. ................................................................................................................. 9
C. Minimum/Maximum Award Information ............................................................................. 10
D. Period of Performance ........................................................................................................... 10
E. Type of Funding Instrument. ................................................................................................. 10
III. Eligibility Information. ........................................................................................................ 10
A. Eligible Applicants. ............................................................................................................... 11
B. Ineligible Applicants. ............................................................................................................ 11
C. Cost Sharing or Matching...................................................................................................... 11
D. Threshold Eligibility Requirements. ..................................................................................... 11
E. Statutory and Regulatory Requirements Affecting Eligibility. ............................................ 12
F. Program-Specific Requirements............................................................................................ 13
G. Criteria for Beneficiaries. ...................................................................................................... 16
IV. Application and Submission Information. ........................................................................... 16
A. Obtaining an Application Package ........................................................................................ 16
B. Content and Form of Application Submission. ..................................................................... 18
C. System for Award Management (SAM) and Dun and Bradstreet Universal Numbering
System (DUNS) Number. .......................................................................................................... 21
D. Application Submission Dates and Times............................................................................. 21
E. Intergovernmental Review. ................................................................................................... 24
F. Funding Restrictions.............................................................................................................. 24
G. Other Submission Requirements. .......................................................................................... 26
V. Application Review Information ........................................................................................... 27
A. Review Criteria...................................................................................................................... 27
B. Review and Selection Process. .............................................................................................. 33
VI. Award Administration Information. .................................................................................... 38
A. Award Notices ....................................................................................................................... 38

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B. Statutory and Administrative, National and Department Requirements for HUD Recipients
................................................................................................................................................... 39
C. Reporting............................................................................................................................... 39
D. Debriefing. ............................................................................................................................ 40
VII. Agency Contact(s). ............................................................................................................. 40
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Other Information .............................................................................................................. 41

APPENDIX................................................................................................................................ 42

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Program Office:
Office of Housing
Funding Opportunity Title:
Notice of Funding Opportunity (NOFO) for the Department's Fiscal Year 2021 Comprehensive
Housing Counseling Grant Program
Funding Opportunity Number:
FR-6500-N-33
Primary CFDA Number:
14.169
Due Date for Applications:
10/14/2021
Overview
The U.S. Department of Housing and Urban Development (HUD) issues this Notice of Funding
Opportunity (NOFO) to invite applications from eligible applicants for the program and purpose
described within this NOFO. Prospective applicants should carefully read all instructions in all
sections to avoid sending an incomplete or ineligible application. HUD funding is highly
competitive. Failure to respond accurately to any submission requirement could result in an
incomplete or noncompetitive proposal.
During the selection process HUD is prohibited from disclosing 1) information regarding any
applicant’s relative standing, 2) the amount of assistance requested by an applicant, and 3) any
information contained in the application. Prior to the application deadline, HUD may not disclose
the identity of any applicant or the number of applicants that have applied for assistance.
For Further Information Regarding this NOFO: Please direct questions regarding the specific
requirements of this Notice of Funding Opportunity (NOFO) to the office contact identified in
Section VII.
Paperwork Reduction Act Statement. The information collection requirements in this notice have
been approved by OMB under the Paperwork Reduction Act of 1995 (44 U.S.C. 35013520). In
accordance with the Paperwork Reduction Act, HUD may not conduct or sponsor, and a person
is not required to respond to, a collection of information unless the collection displays a valid
OMB control number. Each NOFO will identify its applicable OMB control number unless its
collection of information is excluded from these requirements under 5 CFR part 1320.
OMB Approval Number(s):
2502-0261
I. FUNDING OPPORTUNITY DESCRIPTION.
A. Program Description.
1. Purpose
a. Program Description. The purpose of HUD’s Comprehensive Housing Counseling (CHC)
Grant Program is to provide funds to HUD-approved housing counseling agencies that provide
counseling and advice to tenants and homeowners, with respect to property maintenance,
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financial management and literacy, and other matters as may be appropriate to assist program
clients in improving their housing conditions, meeting their financial needs, and fulfilling the
responsibilities of tenancy or homeownership. This NOFO plays an integral role in helping
individuals and families obtain housing and stay in their homes through responsible
homeownership or affordable rental housing. Housing counseling agencies are an important
safeguard in the prevention of housing scams and discrimination and serve as an important
gateway to local, state, federal, and private housing assistance and resources.
b. Objectives and Priorities of this NOFO. The objectives and priorities of this NOFO
include but are not limited to:
1. Distributing federal financial support to eligible housing counseling agencies to enable
them to provide quality services to consumers to address their housing and financial
needs.
2. Distributing federal financial support to eligible Historically Black Colleges and
Universities (HBCU), Tribal Colleges and Universities, and other Minority Serving
Institutions (MSI) to provide quality services to consumers to address their housing
and financial needs.
3. Distributing federal financial support to eligible housing counseling agencies based on
past performance.
4. Reducing the costs to program participants when applying for and reporting on
HUD funding while maintaining accountability for federal funds.
5. Leveraging external resources and funding to increase the sustainability of quality
housing counseling programs.
6. Supporting the housing counseling industry in implementing counselor certification to
increase the quality, consistency, and effectiveness of housing counseling.
7. Ensuring distribution of funding amounts for rural areas with low levels of access to
housing counseling services.
8. Providing housing counseling services to traditionally underserved populations, such as
people of color, seniors, veterans, persons with disabilities, and persons with limited
English proficiency.
2. Changes from Previous NOFO.
Two-Year NOFO. One Competition Distributes Subsequent Year Funding if Available.
HUD will use the grant applications received for FY 2021 and the corresponding scores to make
awards for FY 2022, subject to the availability of appropriations. HUD will contact eligible FY
2021 grantees to determine their interest in FY 2022 funds if available. HUD also reserves the
right to issue a supplemental comprehensive housing counseling NOFO in FY 2022, which may
be limited to new applicants or to provide support for a specific housing counseling activity.
Historically Black Colleges and Universities (HBCU), Tribal Colleges and Universities, and
Minority Serving Institutions (MSI). HUD will provide increased financial support to eligible
HUD-approved housing counseling agencies that demonstrate their status as an HBCU or other
MSI and/or to HUD-approved housing counseling agencies partnering with HBCUs and MSIs.
Changes to Eligibility Information. Applicants and Subgrantees are prohibited from applying
for or receiving FY 2021 CHC Program grant funding from multiple sources. For example,
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applying for funding under this NOFO as both a direct Grantee (e.g. a Local Housing Counseling
Agency (LHCA)) and as a Subgrantee of an Intermediary or SHFA is prohibited. Likewise,
applying for funding under this NOFO as a Subgrantee of two different Intermediaries or as a
Subgrantee of an Intermediary and as a Subgrantee of an SHFA is prohibited. There are no
exceptions to this requirement.
Changes to the Minimum Fundable Score. For FY 2021, HUD anticipates making awards to
all Applicants scoring 75 points or greater.
Change to the Period of Performance. The period of performance for grants awarded under
this program is April 1, 2021, through September 30, 2022.
Changes to the Application Package.
1. Leveraging. Any Applicant with leveraged resources must complete Chart B: Leveraged
Resources (Excel). Applicants will no longer be required to transfer their total leveraging
to form HUD-9906 (PDF). (Note: Unless otherwise specified, the term “Form HUD9906” refers to form HUD-9906-L for LHCA Applicants and to form HUD-9906-P for
Intermediary/SHFA/MSO Applicants).
2. Total Program Expenses. There is a new Chart E: Use of Funds (Excel). All Applicants
must document their total housing counseling program expenses using this chart.
3. Historically Black Colleges and Universities (HBCU), Tribal Colleges and
Universities, and other Minority Serving Institutions (MSI). There is a new Chart F.
This Chart only needs to be completed by Applicants requesting funds dedicated for
HBCUs and other MSIs (and partnerships therewith).
Changes to Preference Points.
1. Applicants do not have to reach a fundable score to be awarded preference points.
2. There are no longer preference points for “Emergency Preparedness/Disaster
Recovery.” Points for “Emergency Preparedness/Disaster Recovery” will be considered
in Rating Factor 2.
Changes to the Funding Methodology and Rating Factor.
1. Funding to Support a Network. HUD may augment an Applicant’s award for oversight
and quality control activities. The bonus will be capped at the lesser of a) five reviews or
b) 50% or less of the Applicants funded network.
0. Definitions.
a. Standard Definitions
Affirmatively Furthering Fair Housing (AFFH). Affirmatively Furthering Fair Housing
(AFFH) means taking meaningful actions, in addition to combating discrimination, that overcome
patterns of segregation and foster inclusive communities free from barriers that restrict access to
opportunity based on protected characteristics. Specifically, affirmatively furthering fair housing
means taking meaningful actions that, taken together, address significant disparities in housing
needs and in access to opportunity, replacing segregated living patterns with truly integrated and
balanced living patterns, transforming racially and ethnically concentrated areas of poverty into
areas of opportunity, and fostering and maintaining compliance with civil rights
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and fair housing laws. The duty to affirmatively further fair housing extends to all of a program
participant’s activities and programs relating to housing and urban development.
Assistance Listings means a unique number assigned to identify a Federal Assistance Listing,
formerly known as the CFDA Number.
Federal Financial Assistance means assistance that entities received or administer in the form
of:
1) Grant;
2. Cooperative agreements (which does not include a cooperative research and development
agreement pursuant to the Federal Technology Transfer Act of 1986, as amended (15
U.S.C. 3710a));
3. Loans;
4. Loan guarantees;
5. Subsidies;
6. Insurance;
7. Food commodities;
8. Direct appropriations;
9. Assessed or voluntary contributions; or
10. Any other financial assistance transaction that authorizes the non-Federal
entity's expenditure of Federal funds.
b. Federal Financial Assistancedoes not include:
1. Technical assistance, which provides services in lieu of money; and
2. A transfer of title to federally owned property provided in lieu of money, even
if the award is called a grant.
Authorized Organization Representative (AOR) is the person authorized to submit
applications on behalf of the organization via Grants.gov. The AOR is authorized by the E-Biz
point of contact in the System for Award Management. The AOR is listed in item 21 on the SF424.
Consolidated Plan is a document developed by states and local jurisdictions. This plan is
completed by engaging in a participatory process to assess their affordable housing and
community development needs and market conditions, and to make data-driven, place-based
investment decisions with funding from formula grant programs. (See 24 CFR part 91 HUD’s
requirements regarding the Consolidated Plan and related Action Plan).
Contract means, for the purpose of Federal financial assistance, a legal instrument by which a
recipient or subrecipient purchases property or services needed to carry out the project or
program under a Federal award. For additional information on contractor and subrecipient
determinations see 2 CFR 200.331.
Contractor means an entity that receives a contract as defined in 2 CFR 200.1.
Deficiency is information missing or omitted within a submitted application. Examples of
deficiencies include missing documents, information on a form, or some other type of unsatisfied
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information requirement (e.g., an unsigned form, unchecked box.). Depending on specific
criteria, deficiencies may be either curable or non-curable.

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Curable Deficiencies may be corrected by the applicant with
timely action. To be curable the deficiency must:
Not be a threshold requirement, except for documentation of
applicant eligibility;
Not influence how an applicant is ranked or scored versus
other applicants; and
Be remedied within the time frame specified in the notice of deficiency.
Non-Curable Deficiencies cannot be corrected by an applicant after
the submission deadline.

Non-curable deficiencies are deficiencies that, if corrected, would change an applicant’s score or
rank versus other applicants. Non-curable deficiencies may result in an application being marked
ineligible, or otherwise adversely affect an application’s score and final determination.
DUNS Number is the nine-digit Dun and Bradstreet Data Universal Number
System identification number assigned to a business or organization by Dun & Bradstreet and
provides a means of identifying business entities on a location-specific basis. OMB removed
duplicate recipients based on recipient Data Universal Number System (DUNS) numbers, from
Dun & Bradstreet (D&B). At this time all Federal financial assistance recipients are required to
register for DUNS numbers.
E-Business Point of Contact (E-Biz POC) A user registered as an organization applicant who
is responsible for the administration and management of grant activities for his or her
organization. The E-Biz POC is likely to be an organization's chief financial officer or
authorizing official. The E-Biz POC authorizes representatives of their organization to apply on
behalf of the organization (see Standard AOR and Expanded AOR). There can only be one EBiz POC per DUNS Number.)
Eligibility requirements are mandatory requirements for an application to be eligible for
funding.
Federal award, has the meaning, depending on the context, in either paragraph (1) or (2) of this
definition:
(1)(i) The Federal financial assistance that a recipient receives directly from a Federal awarding
agency or a subrecipient receives indirectly from a pass-through entity, as described in 2 CFR
§200.101; or
ii.

The cost-reimbursement contract under the Federal Acquisition Regulations that a nonFederal entity receives directly from a Federal awarding agency or indirectly from a passthrough entity, as described in 2 CFR §200.101.

2. The instrument setting forth the terms and conditions. The instrument is the grant
agreement, cooperative agreement, other agreement for assistance covered in paragraph
(2) of the definitions of Federal financial assistance in 2 CFR §200.1, or the costreimbursement contract awarded under the Federal Acquisition Regulations.
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3. Federal award does not include other contracts that a Federal agency uses to buy goods or
services from a contractor or a contract to operate Federal Government owned, contractor
operated facilities (GOCOs).
4. See also definitions of Federal financial assistance, grant agreement, and
cooperative agreement.
Grants.gov is the website serving as the Federal government’s central portal for searching and
applying for Federal financial assistance throughout the Federal government. Registration on
Grants.gov is required for submission of applications to prospective agencies unless otherwise
specified in this NOFO.
Non-Federal Entity (NFE) means a state, local government, Indian tribe, Institution of Higher
Education (IHE), or non-profit organization that carries out a Federal award as a recipient or
subrecipient.
Opportunity Zone (OZs) are defined in 26 U.S.C. 1400Z-1. In general, OZs are census tracts
located in low-income communities where new investments, under certain conditions, may be
eligible for preferential tax treatment.
Point of Contact (POC) is the person who may be contacted with questions about the
application submitted by the AOR. The POC is listed in item 8F on the SF-424.
Promise Zones (PZs) are high poverty communities where the federal government partners with
local leaders to increase economic activity, improve educational opportunities, leverage private
investment, reduce violent crime, enhance public health and address other priorities identified by
the community.
Recipient means an entity, usually but not limited to non-Federal entities, that receives a Federal
award directly from HUD. The term recipient does not include subrecipients or individuals that
are beneficiaries of the award.
Small business is defined as a privately-owned corporation, partnership, or sole proprietorship
that has fewer employees and less annual revenue than a corporation or regular-sized business.
The definition of "small"—in terms of being able to apply for government support and qualify
for preferential tax policy—varies by country and industry. The U.S. Small Business
Administration defines a small business according to a set of standards based on specific
industries.{e-CFR Title 13-Chapter I – Part 121}
Subaward means an award provided by a pass-through entity to a subrecipient for the
subrecipient to carry out part of a Federal award received by the pass-through entity. It does not
include payments to a contractor or payments to an individual that is a beneficiary of a Federal
program. A subaward may be provided through any form of legal agreement, including an
agreement that pass-through entity considers a contract.
Subrecipient means an entity, usually but not limited to non-Federal entities, that receives a
subaward from a pass-through entity to carry out part of a Federal award but does not include an
individual that is a beneficiary of such award. A subrecipient may also be a recipient of other
Federal awards directly for a Federal awarding agency.
System for Award Management (SAM) means the Federal Repository into which an entity
must provide information required for the conduct of business as a recipient. Registration with
SAM is required for submission of applications via Grants.gov. You can access the website
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athttps://www.sam.gov/SAM/. There is no cost to use SAM.
Threshold Requirements are an eligibility requirement that must be met for an application to
be reviewed. Threshold requirements are not curable, except for documentation of applicant
eligibility and are listed in Section III.D Threshold Eligibility Requirements. Similarly, there are
eligibility requirements under Section III.E, Statutory and Regulatory Requirements Affecting
Eligibility.
Unique Entity Identifier means the identifier required for SAM registration to uniquely identify
business entities.
4. Program Definitions
Program specific definitions are available in Appendix A, Definitions.
B. Authority.
HUD's Housing Counseling Program is authorized by Section 106 of the Housing and Urban
Development Act of 1968 (12 U.S.C. § 1701x) (Section 106) and Section 4 of the Department of
Housing and Urban Development Act (42 U.S.C. § 3533) as amended. The Housing Counseling
Program regulations are codified at 24 C.F.R. Part 214. The Home Equity Conversion Mortgage
Program (HECM) is authorized by Section 255 of the National Housing Act (12 U.S.C. § 1715z20), and its regulations are codified at 24 C.F.R. Part 206. Funding for this program is provided
by the Consolidated Appropriations Act, 2021 (Public. Law 116-260, approved December 27,
2020).
II. Award Information.
A. Available Funds
Funding of approximately $ 51,000,000 is available through this NOFO.
Additional funds may become available for award under this NOFO, because of HUD's efforts to
recapture funds, use carryover funds, or because of the availability of additional appropriated
funds. Use of these funds is subject to statutory constraints. All awards are subject to the funding
restrictions contained in this NOFO.
$3,000,000 of the approximately $51,000,000 will be for HUD-approved housing counseling
agencies that are HBCUs or other MSIs and/or for HUD-approved housing counseling agencies
that partner with an HBCU or other MSI to provide counseling and group education.
One Competition Distributes Subsequent Year Funding if Available. HUD will use the grant
applications received for FY 2021 and the corresponding scores to make awards for FY 2022,
subject to the availability of appropriations. HUD will contact eligible FY 2021 grantees to
determine their interest in FY 2022 funds if available. HUD also reserves the right to issue a
supplemental comprehensive housing counseling NOFO in FY 2022, which may be limited to
new applicants or to provide support for a specific housing counseling activity.
B. Number of Awards.
HUD expects to make approximately 250 awards from the funds available under this NOFO.
The number of awards under this NOFO will depend on the number of eligible applicants and
other factors. For information on the methodology used to make award determinations under this
NOFO, see Section V.B.
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C. Minimum/Maximum Award Information
1. Total Grant Request. Applicants are not required to request a specific award amount,
nor provide a proposed budget for a grant amount but should enter a response of $1.00 in
line 18a of the SF-424, Application for Federal Assistance.
2. Award Adjustments. Once Applicants are selected for award, HUD will determine the
total amount to be awarded to each grantee. HUD reserves the right to adjust funding
levels for each grantee.
3. Minimum and Maximum Award Amounts. Applicants may indicate a maximum grant
request that will be considered as a cap in establishing the maximum Comprehensive
Housing Counseling award, up to $3 million.
HBCU and other MSI funds will be awarded to HUD-approved housing counseling agencies in
addition to the maximum award amount.
Estimated Total Funding:
$ 51,000,000
Minimum Award Amount:
$1
Per Project Period
Maximum Award Amount:
$ 3,000,000
Per Project Period
D. Period of Performance
Estimated Project Start Date:
04/01/2021
Estimated Project End Date:
09/30/2022
Length of Project Periods:
18-month project period and budget period
Length of Periods Explanation of Other:
The initial period of performance for grants awarded under this program will be for a period of
18 months. For planning purposes, Applicants should assume that the period of performance is
April 1, 2021 through September 30, 2022.
E. Type of Funding Instrument.
Funding Instrument Type:
G (Grant)
HUD will use a cost reimbursement Grant Agreement, which means that grantees will receive
funding for housing counseling services that were provided prior to a draw request for
reimbursement. Grantees may not draw down on an award made through this NOFO until the
prior year's award has been fully expended.
III. Eligibility Information.
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A. Eligible Applicants.
25 (Others (see text field entitled "Additional Information on Eligibility" for clarification))
Additional Information on Eligibility
1. Eligible applicants must satisfy the following criteria. Applicant must be approved to
participate in the HUD Housing Counseling Program prior to the NOFO issue date. In addition,
SHFAs are eligible for this NOFO if they possess statutory authority to provide housing
counseling throughout their entire state and adhere to all program requirements outlined in 24
CFR Part 214, HUD Handbook 7610.1 Rev-5, and other governing policies and requirements.
2. Limits on Applicants. Applicants and Subgrantees are prohibited from receiving FY 2021
Housing Counseling Program grant funding from multiple sources. For example, receiving
funding under this NOFO as both a direct Grantee (e.g. LHCA) and as a Subgrantee of an
Intermediary or SHFA is prohibited. Likewise, receiving funding under this NOFO as a
Subgrantee of two different Intermediaries/SHFAs is prohibited.
B. Ineligible Applicants.
Applicants that do not meet the criteria of Section III.A. are ineligible.
C. Cost Sharing or Matching.
This Program does not require cost sharing or matching, but provides points based on leverage as
describe below.
See Rating Factor 4: Leveraging Resources in Section V.A.
D. Threshold Eligibility Requirements.
Applicants who fail to meet any of the following threshold eligibility requirements will
be deemed ineligible. Applications from ineligible applicants will not be evaluated.
1. Resolution of Civil Rights Matters. Outstanding civil rights matters must be resolved before
the application deadline. Applicants, who after review are confirmed to have civil rights matters
unresolved at the application deadline, will be deemed ineligible. Their applications will receive
no further review, will not be rated and ranked, and they will not receive funding.
a. Applicants having any of the charges, cause determinations, lawsuits, or letters of
findings referenced in subparagraphs (1) – (5) that have not been resolved to HUD’s
satisfaction before or on the application deadline date are ineligible for funding.
Such matters include:
1. Charges from HUD concerning a systemic violation of the Fair Housing Act or
receipt of a cause determination from a substantially equivalent state or local fair
housing agency concerning a systemic violation of a substantially equivalent state or
local fair housing law proscribing discrimination because of race, color, religion,
sex, national origin, disability or familial status;
2. Status as a defendant in a Fair Housing Act lawsuit filed by the Department of
Justice alleging a pattern or practice of discrimination or denial of rights to a group
of persons raising an issue of general public importance under 42 U.S.C. 3614(a);
3. Status as a defendant in any other lawsuit filed or joined by the Department of Justice,
or in which the Department of Justice has intervened, or filed an amicus brief
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or statement of interest, alleging a pattern or practice or systemic violation of Title
VI of the Civil Rights Act of 1964, Section 504 of the Rehabilitation Act of 1973,
Section 109 of the Housing and Community Development Act of 1974, the
Americans with Disabilities Act or a claim under the False Claims Act related to fair
housing, non-discrimination, or civil rights generally including an alleged failure to
affirmatively further fair housing;
4. Receipt of a letter of findings identifying systemic non-compliance with Title VI of
the Civil Rights Act of 1964, Section 504 of the Rehabilitation Act of 1973,
Section 109 of the Housing and Community Development Act of 1974; or the
Americans with Disabilities Act; or
5. Receipt of a cause determination from a substantially equivalent state or local fair
housing agency concerning a systemic violation of provisions of a state or local law
prohibiting discrimination in housing based on sexual orientation, gender identity,
or lawful source of income.
b. HUD will determine if actions to resolve the charge, cause determination, lawsuit, or
letter of findings taken before the application deadline date will resolve the matter.
Examples of actions that may be sufficient to resolve the matter include, but are not
limited to:
1. Current compliance with a voluntary compliance agreement signed by all the parties;
2. Current compliance with a HUD-approved conciliation agreement signed by all
the parties;
3. Current compliance with a conciliation agreement signed by all the parties and
approved by the state governmental or local administrative agency with
jurisdiction over the matter;
4. Current compliance with a consent order or consent decree;
5. Current compliance with a final judicial ruling or administrative ruling or decision; or
6. Dismissal of charges.
2. Timely Submission of Applications. Applications submitted after the deadline stated within
this NOFO that do not meet the requirements of the grace period policy will be marked late. Late
applications are ineligible and will not be considered for funding. See Section IV. D. Application
Submission Dates and Times.
E. Statutory and Regulatory Requirements Affecting Eligibility.
Eligibility Requirements for Applicants of HUD’s Grants Programs
The following requirements affect applicant eligibility. Detailed information on each
requirement is posted on HUD’s Funding Opportunities Page.

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Active Prime and Sub Recipient registration with SAM.gov
Outstanding Delinquent Federal Debts
Debarments and/or Suspensions
Pre-selection Review of Performance
Sufficiency of Financial Management System
False Statements
Mandatory Disclosure Requirement
Prohibition Against Lobbying Activities
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 Equal Participation of Faith-Based Organizations in HUD Programs and Activities
F. Program-Specific Requirements.
1. Audits and Investigations. Successful Applicants must provide the most recent audit of
financial activities (e.g., a single or program-specific audit required under 2 C.F.R.
§200.501) completed no earlier than fiscal year 2018. All Applicants not required to
complete a single or program-specific audit under 2 C.F.R. §200.501 must submit their
most recent independent financial audit. HUD will review individual circumstances upon
request.
At the time of the NOFO application submission date and thereafter, all Applicants must
disclose to HUD the status of active investigations as outlined in 24 CFR § 214.103(c)(3).
HUD may determine that Applicants are not eligible for grant funding based on its review
of HUD, HUD Office of Inspector General (OIG), or other government audits or
investigations.
2. Client Management System. All Applicants, Branches, and Subgrantees must use a
HUD-compliant Client Management System (CMS) that interfaces with HUD’s Housing
Counseling System (HCS). HUD will review individual circumstances when an agency is
transitioning CMSs.
3. Subgrant Allocation. Applicants that manage networks of counseling agencies must
submit a proposed sub-allocation plan indicating how they will divide their HUD CHC
Grant funds among their Branches and Subgrantees, based on percentages of the grant
rather than dollar amounts (see Form HUD-9906-P, Chart A2, Fields P1 and P2). Only
Subgrantees and Branches that provide housing counseling services should be listed.
Subgrantees or Branches that perform only administrative functions should not be listed.
Intermediaries and SHFAs that award subgrants to counseling agencies that are not HUDapproved must ensure that they meet or exceed HUD’s approval standards as outlined in
24 C.F.R. Part 214 and clarified in HUD policy guidance. Further, a Subgrantee cannot be
funded at 100% of its budget. During grant execution, Grantees will input this suballocation plan into HCS. If, after the grants are awarded, a Grantee would like to change
its sub-allocation plan, the Grantee must make a request in writing and provide
justification.
4. Subgrant Agreement. Intermediaries and SHFAs that award subgrants must execute
subgrant agreements with Subgrantees that delineate the mutual responsibilities for
program management, including appropriate time frames for reporting results to HUD
and compliance with HUD rules and regulations. These records must meet the data
requirements of the Federal Funding Accountability and Transparency Act of 2006
(FFATA) (P.L. 109-282), and must be made available to Subgrantees, Branches, and
HUD within 30 days of making the subaward or allocation.
5. Succession and Contingency Plans. Grantees shall make available to HUD, upon
request, plans demonstrating how they will ensure continuity of services to consumers.
6. Documentation of Expenses. All Grantees and Subgrantees must be able to demonstrate
and document the actual cost of service provision. The amount billed cannot exceed the
actual cost of providing the service. The Grantee and Subgrantees must maintain source
documentation of direct costs, such as invoices, receipts, cancelled checks, and personnel
activity reports, to support all Line of Credit Control System (LOCCS) draw requests for
payment. This information must be made available upon request and maintained for a
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period of at least three years after the expiration of the Grant period or date of last
payment, whichever occurs first.
7. Documentation of Personnel Expenses. Charges to Federal awards for salaries and
wages must be based on records that accurately reflect the work performed and meet the
standards required in 2 C.F.R Part 200.430(i). The records must support the distribution
of employee’s salaries and wages among specific activities or cost objectives if the
employee works on more than one Federal award; a Federal award and non-Federal
award; an indirect cost activity and a direct cost activity; two or more indirect activities
which are allocated using different allocation bases; or an unallowable activity and a
direct or indirect cost activity. Budget estimates alone do not qualify as support for
charges to awards. Records must reasonably reflect the total activity for which employees
are compensated.
8. Subcontracting. Grantees and Subgrantees must deliver the housing counseling services
set forth in the Applicant’s Work Plan. It is not permissible to contract out housing
counseling services, except as approved by HUD as specified in 24 C.F.R. § 214.103(i).
9. Conflicts of Interest. See 24 C.F.R. Part 214 and Handbook 7610.1 for information
about the Applicant’s code of conduct and the prohibition against real and apparent
conflicts of interest that may arise among officers, employees, agents, or other parties.
10. Affirmatively Furthering Fair Housing (AFFH). Under Section 808(e)(5) of the Fair
Housing Act, HUD has a statutory duty to affirmatively further fair housing and requires
the same of its funding recipients: As provided in the AFFH rule (24 CFR § 5.151),
“Affirmatively furthering” means: “taking meaningful actions that, taken together,
address significant disparities in housing needs and in access to opportunity, replacing
segregated living patterns with racially balanced living patterns, transforming racially or
ethnically concentrated areas of poverty into areas of opportunity, and fostering and
maintaining compliance with civil rights and fair housing laws.” “Meaningful actions”
are significant actions that are designed and can be reasonably expected to achieve a
material positive change that affirmatively furthers fair housing by, for example,
increasing fair housing choice or decreasing disparities in access to opportunity.
Specifically, action must be taken to fulfill, as much as possible, the goal of open,
integrated residential housing patterns and to prevent the increase of segregation, of
racial groups whose lack of opportunities the Act was designed to combat.
Examples of housing counseling activities that would be consistent with the obligation to
AFFH include, but are not limited to, the following:
a. Providing persons with counseling, education, or information on discriminatory
housing and mortgage lending practices and the rights and remedies available.
b. Maintaining a data base of accessible housing opportunities in the community and
providing database for use by LEP persons or persons with disabilities.
c. Providing mobility counseling to help persons move to and access affordable
housing in the community, including helping persons identify housing
opportunities, helping them connect with landlords, and assisting them with
applying for such housing.
11. Prohibition Against Lobbying Activities. Applicants are subject to the provisions of
Section 319 of Pub L No. 101-121, 31 U.S.C. § 1352 (the Byrd Amendment), 24 CFR
Part 87, and 2 CFR §200.450, which prohibit recipients of Federal awards and their
Page 14 of 43

contractors, subcontractors, at any tier, and Subgrantees at any tier, from using
appropriated funds for lobbying the executive or legislative branches of the federal
government in connection with a Federal award. In addition, grant funds under this
NOFO shall not be utilized to advocate or influence the outcome of any federal, state
or local election, referendum, initiative, or similar procedure or policy position through
contributions, endorsements, publicity, or similar activity.
12. Tax Exempt. Applicants, Subgrantees, and Branches must be:
a. exemption from taxation under Internal Revenue Code (IRC) Section 501 (a) as
an entity described in IRC Section 501(c) (26 U.S.C. § 501 (a) and (c)), or units
of local, county, or state government,
b. in good standing under the laws and regulations of the state of their organization,
and
c. authorized to do business in the states in which they propose to provide housing
counseling services.
13. Provide Accessible Services. Applicants receiving federal financial assistance shall
operate their housing programs or activities so that they are readily accessible to and
usable by persons with disabilities. All programs or activities must be held in accessible
locations, and successful applicants must give priority to methods that provide physical
access to individuals with disabilities. Applicants receiving federal financial assistance
shall administer their housing programs or activities in the most integrated setting
appropriate to the needs of individuals with
disabilities. Section 504 of the Rehabilitation Act of 1973 (29 U.S.C. § 794) and HUD’s
implementing regulations at 24 CFR part 8; Titles II and III of the Americans with
Disabilities Act (42 U.S.C 12101 et seq.) and its implementing regulations at 28 CFR
parts 35 and 36.
In addition, counseling services must comply with effective communication and
reasonable accommodation requirements pursuant to Section 504 of the Rehabilitation
Act of 1973 and HUD’s implementing regulations at 24 C.F.R. part 8 and Titles II and
III of the Americans with Disabilities Act of 1990, and the Department of Justice
implementing regulations codified at 28 C.F.R. parts 35 and 36.
Accessibility arrangements, auxiliary aids and services, and reasonable accommodations
may include, but are not limited to, materials provided in different formats, including
large print or Braille and interpreter services. Information on how to request available
assistive services and reasonable accommodations must be available, as well as available
in different formats. Regarding accessible technology, HUD requires its funding
recipients to adopt the goals and objectives of Section 508 of the Rehabilitation Act of
1973 by ensuring, whenever electronic and information technology (EIT) is used,
procured, or developed, that persons with disabilities have access to and use of the
information and data made available through the EIT on a comparable basis as is made
available to and used by persons without disabilities.
Further, Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d et seq., and Executive
Page 15 of 43

Order 13166 require that grantees take reasonable steps to ensure meaningful access to
services, programs, and activities by persons with Limited English Proficiency. For
assistance, grantees should consult HUD’s Final Guidance to Federal Financial
Assistance Recipients Regarding Title VI Prohibition Against National Origin
Discrimination Affecting Limited English Proficient Persons (HUD’s LEP Guidance)
published in the Federal Register on January 22, 2007 (72 Fed. Reg. 2732).
14.
Sam.gov and DUNS Registration Requirement. Applicants must have a
valid, active registration in the SAM. In addition, applicants and subgrantees must have
a DUNS Number.
15.
Outstanding Performance Issues. Applicants and Subgrantees must
resolve all outstanding issues communicated by HUD in writing by the later of the
application deadline date of this NOFO or the expiration date of any conditional reapproval or inactive status resulting from such written communication.
16.
Election for Federal Office Violation. No Applicant, Subgrantee, or Branch that
employs an individual who has been convicted of a violation under federal law relating to
an election for Federal office. See 12 U.S.C. 1701x(a)(4)(D).
17.
Housing Counseling Work Plan. Applicants must have an approved Housing
Counseling Work Plan on file with HUD. Activities specified in the form HUD-9906
Housing Counseling Charts must be consistent with activities previously approved in the
work plan prior to the application due date. Applicants are reminded of the requirement to
provide counseling to at least thirty clients annually (24 CFR § 214.303(b)).
18.
Compliance with Third Party Certifications and Licensing. Applicants must
comply with, and not in default under, any applicable state or other licensing and
certification requirements. HUD will review individual circumstances upon request.
19.
Inherently Religious Activities. If an organization engages in inherently religious
activities, such as worship, religious instruction, or proselytization, these activities must
be offered separately, in time or location, from the programs or services funded under this
part, and participation must be voluntary and not a condition of the HUD programs or
services in accordance with 24 CFR § 5.109(e).
G. Criteria for Beneficiaries.
IV. Application and Submission Information.
A. Obtaining an Application Package.
Instructions for Applicants.
You must download both the Application Instructions and the Application Package from
Grants.gov. You must verify that the Assistance Listing Number and Assistance Listing
Description on the first page of the Application Package, and the Funding Opportunity Title and
the Funding Opportunity Number match the Program and NOFO to which you are applying.
The Application Package contains the portable document forms (PDFs) available on Grants.gov,
such as the SF-424 Family. The Instruction Download contains official copies of the NOFO and
forms necessary for a complete application. The Instruction Download may include Microsoft
Word, Microsoft Excel and additional documents.
An applicant demonstrating good cause may request a waiver from the requirement for electronic
submission, for example, a lack of available Internet access in the geographic area in which your
Page 16 of 43

business offices are located. Lack of SAM registration or valid DUNS Number is not good
cause. If you cannot submit your application electronically, you must ask in writing for a waiver
of the electronic grant submission requirements. HUD will not grant a waiver if HUD does not
receive your written mailed, shipped, or emailed request at least 15 calendar days before the
application deadline and if you do not demonstrate good cause. If HUD waives the requirement,
HUD must receive your paper application before the deadline of this NOFO. To request a
waiver, you must contact:
Name:
Email:
[email protected]
HUD Organization:
Street:
City:
State:
Zip:
Waiver requests must be submitted with the subject line “NOFO - Request for Waiver of
Electronic Application.”
NOFO applications and forms are available from http://www.grants.gov/web/grants/applicants
/apply-for-grants.html. Below are basic instructions for obtaining the application instructions and
package:
1. Go to the “Package” tab of the Grant Opportunity. Click “Preview” to view the
instructions and application package. Click “Apply” and “Create a Workspace” to access
fillable forms and begin the application process.
2. Click “Download Instructions” to download a WinZip folder containing the following
files:
a. Comprehensive Housing Counseling NOFO (PDF)
b. Form HUD-9906-L, Local Housing Counseling Agency Application (PDF)
c. Form HUD-9906-P, Intermediary, State Housing Finance Agency, and MultiSate Organization Application (PDF)
d. Form HUD-9906, Chart A2 Supplement (for Intermediaries, SHFAs, and
MSOs) (Excel)
e. Form HUD-9906, Chart B: Leveraged Resources (Excel)
f. Form HUD-9906, Chart E: Use of Funds (Excel)
g. Form HUD-50153, Certification of Consistency with Promise Zone Goals
and Implementation (PDF)
3. The Grants.gov Workspace will list Mandatory and Optional forms, fillable as PDFs or
webforms, if available. Applicants must complete all required fields and upload the
Mandatory forms in order for Grants.gov to allow submission of the application package.
Grants.gov may not permit submission of an incomplete or improperly filled-out form.
4. To add required attachments (like Form HUD-9906, supplemental spreadsheets, etc.),
click "Include in Package" to use the “Attachments Form.” Click the “Add Attachment”
box to attach documents and forms.
5. When the application is complete, you may click “Check Package for Errors.”
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6. To submit the completed application on behalf of the organization, an Authorized
Organization representative must click “Sign and Submit.” Applications may not be
received by Grants.gov or by HUD until they have been signed and submit by an AOR
prior to the application deadline. For the SF-424, Form HUD-2880, and Certification
Regarding Lobbying, the signature of the authorized representative and the date signed
are completed upon submission.
If Applicants have difficulty accessing the information, Applicants may call the help desk at
(800) 518-GRANTS or e-mail [email protected]. Persons who are deaf or hard of hearing, or
who have speech disabilities, may contact customer support through the Federal Relay Service's
teletype service at 1-800-877-8339. The Grants.gov help desk is available 24 hours a day, 7
days per week, except federal holidays.
B. Content and Form of Application Submission.
You must verify that boxes 11, 12, and 13 on the SF-424 match the NOFO for which you are
applying. If they do not match, you have downloaded the wrong Application Instruction and
Application Package.

Submission of an application that is otherwise sufficient, under the wrong Assistance Listing and
Funding Opportunity Number is non curable unless otherwise stated in Threshold requirements.
1. Content.
Forms/Assurances/Certifications

Submission
Notes/Description
Requirement

Submission is
required for
Application for Federal Assistance all applicants
(SF424)
by the
application
due date.

Disclosure of Lobbying Activities
(SFLLL), if applicable

If any funds have been paid or will be
paid to any person for influencing or
attempting to influence an officer or
HUD will
employee of any agency, a Member of
provide
Congress, an officer or employee of
instructions to Congress, or an employee of a Member
grantees on
of Congress in connection with this
how the form commitment providing for the United
States to insure or guarantee a loan, the
is to be
submitted.
applicant shall complete and submit the
SF-LLL, "Disclosure Form to Report
Lobbying," in accordance with its
instructions. Applicants must furnish
Page 18 of 43

Forms/Assurances/Certifications

Submission
Notes/Description
Requirement
an executed copy of the Certification
Regarding Lobbying prior to award.

HUD Applicant Recipient
Disclosure Report (HUD) 2880
Applicant/Recipient
Disclosure/Update Report

HUD will
provide
instructions
to grantees
on how the
form is to be
submitted.

HUD instructions to grantees are
provided by webcast, To view the
webcast, click here.

Additionally, your complete application must include the following narratives and non-form
attachments.
See Application Checklist below for a list of required content.
2. Format and Form.
Narratives and other attachments to your application must follow the following format
guidelines.
_________ Pages maximum length of narratives
a. Application Checklist (Required of all Applicants). Below are forms, information, and
certifications that all Applicants must complete. Failure to complete and submit these forms may
result in loss of points or disqualification.
1. SF-424, Application for Federal Assistance. Applicants should check "new" for block
2 for "Type of Application." Applicants may leave blocks 4, 5a, and 5b blank. For block
8c of the form, ensure that your DUNS Number is correct and is listed on SAM.gov with
an active registration. In block 8d, you must include a 9-digit number for your
organization’s zip code (zip plus 4 digits). Applicants are not required to request a
specific grant amount, but should enter a response of $1.00 in block 18a.
2. Form HUD-2880 Applicant/Recipient Disclosure/Update Report. Applicants must
complete the Form HUD-2880. Applicants should check the box "Initial Report." In
block 4, "Amount of HUD Assistance Requested/Received" of this form, Applicants
may enter $1.00: HUD will not use this amount as a cap in establishing the maximum
grant amount for the Applicant (Applicants may indicate a maximum grant amount in
the Form HUD-9906). Applicants that have received or expect to receive HUD
assistance for housing counseling in excess of $200,000 during FY 2021 must select
"yes" under the second question in "Part I Threshold Determinations.” Detailed
instructions for completing the form are found at this link: http://portal.hud
.gov/hudportal/documents/huddoc?id=2880 .pdf.
3. Form HUD-9906 Housing Counseling Charts. LHCA applicants must complete and
submit form HUD-9906-L (PDF). Intermediary/SHFA/MSO applicants must complete
and submit the HUD-9906-P (PDF) and the Chart A2 Supplement (Excel). All applicants
Page 19 of 43

must complete the form HUD-9906, Chart E: Use of Funds (Excel). All Applicants
with leveraged funds must complete the Chart B: Leveraged Resources (Excel).
Applicants may not reuse the form HUD-9906 from previous applications.
4. Certification Regarding Lobbying (Grants.gov Lobbying Form). All applicants must
complete the Certification Regarding Lobbying to ensure applicants acknowledge the
requirements in the Byrd Amendment and 24 CFR Part 87. These statutes and regulation
prohibit the use of Federal award funds for lobbying the executive or legislative branches
of the Federal government in connection with a specific award. This is separate from the
requirement for Applicants to report lobbying activities using SF-LLL.
b. Application Checklist - Additional Items (Applicable Only to Certain Applicants).
Below are forms, information, and certifications that certain Applicants must include
depending on their individual circumstances:
1. Form HUD-50153, Certification of Consistency with Promise Zone Goals and
Implementation. Applicants requesting Promise Zone preference points must submit a
form signed by the authorized official for the designated Promise Zone.
2. Form HUD-9902, Housing Counseling Agency Fiscal Year Activity Report, for
the Period October 1, 2019 through September 30, 2020. Applicants will be
evaluated based on HUD-9902 data in HUD's HCS. Newly approved Applicants that
received approval as HUD housing counseling agencies after September 30, 2020 and
did not submit a Fiscal Year 2020 Quarter 4 HUD-9902 by January 1, 2021, must
prepare and submit a form HUD-9902 as part of the application for the period October
1, 2019 through September 30, 2020.
3. SF-LLL, Disclosure of Lobbying Activities.
4. SHFA Statutory Authority. SHFAs must submit evidence of their statutory authority to
operate as a SHFA, as defined in this NOFO, and must submit evidence of their authority
to apply for funds and subsequently use any funds awarded. Applicants should verify that
their agency profile information is accurately represented in HUD’s HCS and validate the
information prior to submitting the grant application. HUD will contact SHFA Applicants
that are new to the program to establish their profiles in the HCS.
5. Form HUD-2996 Certification for Opportunity Zone Preference Points.
Applicants must complete and submit this form in order to be eligible for Opportunity
Zone preference points.
6. Historically Black Colleges and Universities (HBCU): Preference Points. An
Applicant partnering with a Historically Black College or University will receive up to
two (2) Preference Points when the application includes a Letter of Commitment
certifying that an HBCU Partnership is in place and signed by an authorizing official of
the HBCU and documentation of the college or university's status as an HBCU.
7. Historically Black Colleges and Universities (HBCU), Tribal Colleges and
Universitiies, and other Minority Serving Institutions (MSI). Applicants requesting
funds dedicated for HBCUs and other MSIs (and partnerships therewith) must submit
evidence of the college or university’s status as an HBCU or MSI. Additionally,
Applicants that are partnering with an HBCU or other MSI must submit a letter certifying
that an HBCU or other MSI partnership is in place or that there is an intent to enter a
partnership. The letter must be signed by the Applicant and an authorizing official of the

Page 20 of 43

HBCU or other MSI and the Applicant must provide documentation of the partnering
college or university's status as an HBCU or other MSI.
C. System for Award Management (SAM) and Dun and Bradstreet Universal Numbering
System (DUNS) Number.
1. SAM Registration Requirement.
Applicants must be registered with https://www.sam.gov/ before submitting their application.
Applicants must maintain current information in SAM on immediate and highest-level owner
and subsidiaries, as well as on all predecessors that have been awarded a Federal contract or
grant within the last three years, if applicable. Information in SAM must be current for all times
during which the applicant has an active Federal award or an application or plan under
consideration by HUD.
2. DUNS Number Requirement.
Applicants must provide a valid DUNS number, registered and active at https://www.sam.gov/ in
the application. DUNS numbers may be obtained for free from Dun & Bradstreet.
3. Requirement to Register with Grants.gov.
Anyone planning to submit applications on behalf of an organization must register at grants.gov
and be approved by the E-Biz POC in SAM to submit applications for the organization.
Registration for SAM and grants.gov is a multi-step process and can take four (4) weeks or
longer to complete if data issues arise. Applicants without a valid registration cannot apply
through grants.gov. Complete registration instructions and guidance are provided on grants.gov.
D. Application Submission Dates and Times.
Application Due Date Explanation
The application deadline is 11:59:59 PM Eastern Standard time on
10/14/2021
Applications must be received no later than the deadline, or, if HUD has issued you a waiver
allowing you to submit your application in paper form, by HUD no later than the deadline.
Submit your application to Grants.gov unless a waiver has been issued allowing you to submit
your application in paper form. Instructions for submitting your paper application will be
contained in the waiver of electronic submission.
"Received by Grants.gov" means the applicant received a confirmation of receipt and an
application tracking number from Grants.gov. Grants.gov then assigns an application tracking
number and date-and timestamps each application upon successful receipt by the Grants.gov
system. A submission attempt not resulting in confirmation of receipt and an application tracking
number is not considered received by Grants.gov.
Applications received by Grants.gov must be validated by Grants.gov to be received by HUD.
"Validated by Grants.gov" means the application has been accepted and was not rejected with
errors. You can track the status of your application by logging into Grants.gov, selecting
"Applicants" from the top navigation, and selecting “Track my application” from the dropdown
Page 21 of 43

list. If the application status is "rejected with errors,” you must correct the error(s) and resubmit
the application before the 24-hour grace period ends. Applications in “rejected with errors” status
after the 24-hour grace period expires will not be received by HUD. Visit Grants.gov for a
complete description of processing steps after applying.
HUD strongly recommends you submit your applications at least 48 hours before the
deadline and during regular business hours to allow enough time to correct errors or overcome
other problems.
Grants.gov Customer Support. Grants.gov provides customer support information on its
website at https://www.grants.gov/web/grants/support.html . Applicants having difficulty
accessing the application and instructions or having technical problems can receive customer
support from Grants.gov by calling (800) 518-GRANTS (this is a toll-free number) or by
sending an email to [email protected]. The customer support center is open 24 hours a day,
seven days per week, except Federal holidays. The phone number above may also be reached by
individuals who are deaf or hard of hearing, or who have speech disabilities, through the Federal
Relay Service’s teletype service at 800-877-8339.
You can verify the contents of your submitted application to confirm Grants.gov received
everything you intended to submit. To verify the contents of your submitted application:








Log in to Grants.gov.
Click the Check Application Status link, which appears under the Grant Applications
heading in the Applicant Center page. This will take you to the Check Application Status
page.
Enter search criteria and a date range to narrow your search results.
Click the Search button. To review your search results in Microsoft Excel, click the
Export Data button.
Review the Status column, to view more detailed submission information, click the
Details link in the Actions column.
To download the submitted application, click the Download link in the Actions column.

Please make note of the Grants.gov tracking number as it will be needed by the Grants.gov Help
Desk if you seek their assistance.
HUD may extend the application deadline for any program if Grants.gov is offline or not
available to applicants for at least 24 hours immediately prior to the deadline date, or the system
is down for 24 hours or longer and impacts the ability of applicants to cure a submission
deficiency within the grace period.
HUD may also extend the application deadline upon request if there is a presidentially declared
disaster in the applicant’s area.
If these events occur, HUD will post a notice on its website establishing the new, extended
deadline for the affected applicants. HUD will also include the fact of the extension in the
program’s Notice of Funding Awards required to be published in the Federal Register.
In determining whether to grant a request for an extension based on a presidentially-declared
Page 22 of 43

disaster, HUD will consider the totality of the circumstances including the date of an applicant’s
extension request (how closely it followed the basis for the extension), whether other applicants
in the geographic area are similarly affected by the disaster, and how quickly power or services
are restored to enable the applicant to submit its application.
PLEASE NOTE: Busy servers, slow processing, large file sizes, improper registration or
password issues are not valid circumstances to extend the deadline dates or the grace period.
1. Amending or Resubmitting an Application.
Before the submission deadline, you may amend a validated application through Grants.gov by
resubmitting a revised application containing the new or changed material. The resubmitted
application must be received and validated by Grants.gov by the applicable deadline.
If HUD receives an original and a revised application for a single proposal, HUD will evaluate
only the last submission received by Grants.gov before the deadline.
2. Grace Period for Grants.gov Submissions.
If your application is received by Grants.gov before the deadline, but is rejected with errors, you
have a grace period of 24 hours after the application deadline to submit a corrected, received, and
validated application through Grants.gov. The date and time stamp on the Grants.gov system
determines the application receipt time. Any application submitted during the grace period not
received and validated by Grants.gov will not be considered for funding. There is no grace period
for paper applications.
3. Late Applications.
An application received after the NOFO deadline date that does not meet the Grace Period
requirements will be marked late and will not be received by HUD for funding consideration.
Improper or expired registration and password issues are not causes that allow HUD to accept
applications after the deadline.
4. Corrections to Deficient Applications.
HUD will not consider information from applicants after the application deadline.
HUD will uniformly notify applicants of each curable deficiency. See curable deficiency in the
definitions section (Section I.A.3). Examples of curable (correctable) deficiencies include
inconsistencies in the funding request and failure to submit required certifications. These
examples are non-exhaustive.
When HUD identifies a curable deficiency, HUD will notify the authorized organization
representative identified on the SF 424 Application for Federal Assistance via email. This email
is the official notification of a curable deficiency.
Applicants must email corrections of curable deficiencies to [email protected] within
the time limits specified in the notification. The time allowed to correct deficiencies will be no
less than 48 hours and no more than 14 calendar days from the date of the email notification. The
start of the cure period will be the date stamp on the email sent from HUD. If the deficiency cure
Page 23 of 43

deadline date falls on a Saturday, Sunday, Federal holiday, or on a day when HUD’s
Headquarters are closed, then the applicant’s correction must be received on the next business
day HUD Headquarters offices in Washington, DC are open.
The subject line of the email sent to [email protected] must state: Technical Cure and
include the Grants.gov application tracking number or the GrantSolutions application number
(e.g., Subject: Technical Cure - GRANT123456 or Technical Cure - XXXXXXXXXXX). If this
information is not included, HUD cannot match the response with the application under review
and the application may be rejected due to the deficiency.
Corrections to a paper application must be sent in accordance with and to the address indicated in
the notification of deficiency. HUD will treat a paper application submitted in accordance with a
waiver of electronic application containing the wrong DUNS number as having a curable
deficiency. Failure to correct the deficiency and meet the requirement to have a DUNS number
and active registration in SAM will render the application ineligible for funding.
5. Authoritative Versions of HUD NOFOs. The version of these NOFOs as posted
on Grants.gov are the official documents HUD uses to solicit applications.
6. Exemptions. Parties that believe the requirements of the NOFO would impose a substantial
burden on the exercise of their religion should seek an exemption under the Religious Freedom
Restoration Act (RFRA).
E. Intergovernmental Review.
This program is not subject to Executive Order 12372, Intergovernmental Review of Federal
Programs.
F. Funding Restrictions.
Eligible Activities HUD requires Grantees to use grant funds for housing counseling and group
education in accordance with 24 CFR Part 214 and Handbook 7610.1. To be eligible for
reimbursement as direct costs, costs must be incurred pursuant to one or more of the following
activities:
1.
2.
3.
4.
5.

Housing counseling and group education
Oversight, compliance, and quality control
Supervision of housing counseling staff
Housing counselor training and certification
Marketing and outreach of the CHC Program

HUD will respect cost classifications determined in a negotiated indirect cost rate agreement
(NICRA) or cost allocation plan. HUD may require Applicants to provide documentation
supporting classification of direct and indirect costs. HUD will not reimburse as direct costs
those items that are classified as indirect costs in cost rate calculations and applications (See 2
CFR §§200.403, 200.412, and 200.414). Applicants may choose to take a 10% de minimis
indirect cost rate as provided in the Uniform Guidance to cover indirect costs.
To be eligible for reimbursement, housing counseling or group education performed on or after
Page 24 of 43

the Final Compliance Date, must be provided by a HUD-certified housing counselor (See 24
CFR §214.103(n) Certification of Housing Counselors and updated guidance).
Program Costs Incurred Prior to the Period of Performance. Unless prior approval by HUD
of allowability of costs is required under 2 CFR part 200, Applicants may, pursuant to 2 CFR
200.308, revise budget and program plans and OHC may provide reimbursements for eligible
costs incurred during the period prior to HUD making an award but no earlier than October 1,
2020.Applicants should indicate whether they intend to seek reimbursement for such costs on
form HUD-9906, Chart A, Field R. All costs incurred before the federal awarding agency makes
the federal award are at the recipient's risk (i.e., the federal awarding agency is not required to
reimburse such costs if the recipient does not receive a federal award or if the federal award is
less than anticipated and inadequate to cover such costs).
Indirect Cost Rate.
Normal indirect cost rules under 2 CFR part 200, subpart E apply. If you intend to charge indirect
costs to your award, your application must clearly state the rate and distribution base you intend
to use. If you have a Federally negotiated indirect cost rate, your application must also include a
letter or other documentation from the cognizant agency showing the approved rate. Successful
applicants whose rate changes after the application deadline must submit new rate and
documentation.

Applicants other than state and local governments. If you have a Federally negotiated indirect
cost rate, your application must clearly state the approved rate and distribution base and must
include a letter or other documentation from the cognizant agency showing the approved rate. If
your agency does not have a current negotiated rate (including provisional) rate and elects to use
the de minimis rate, your application must clearly state you intend to use the de minimis rate of
10% of Modified Total Direct Costs (MTDC). As described in 2 CFR 200.403, costs must be
consistently charged as either indirect or direct costs but may not be double charged or
inconsistently charged as both. Once elected, the de minimis rate must be applied consistently for
all Federal awards until you choose to negotiate for a rate, which you may apply to do at any
time. Documentation of the decision to use the de minimis rate must be retained on file for audit.
State and local governments. If your department or agency unit has a Federally negotiated
indirect cost rate, your application must include that rate, the applicable distribution base, and a
letter or other documentation from the cognizant agency showing the negotiated rate. If your
department or agency unit receives more than $35 million in direct Federal funding per year, you
may not claim indirect costs until you receive a negotiated rate from your cognizant agency for
indirect costs as provided in Appendix VII to 2 CFR Part 200.
If your department or agency unit receives no more than $35 million in direct Federal funding per
year and your department or agency unit has developed and maintains an indirect cost rate
proposal and supporting documentation for audit in accordance with 2 CFR Part 200, Appendix
VII, you may use the rate and distribution base specified in that indirect cost rate proposal.
Alternatively, if your department or agency unit receives no more than $35 million in direct
Federal funding per year and does not have a current negotiated rate (including provisional) rate,
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you may elect to use the de minimis rate of 10% of MTDC. As described in 2 CFR 200.403,
costs must be consistently charged as either indirect or direct costs but may not be double
charged or inconsistently charged as both. Once elected, the de minimis rate must be applied
consistently for all Federal awards until you choose to negotiate for a rate, which you may apply
to do at any time. Documentation of the decision to use the de minimis rate must be retained on
file for audit.
G. Other Submission Requirements.
1. Application, Assurances and Certifications.
Standard Form 424 (SF-424) Application for Federal Assistance Programs is the governmentwide form required to apply for Application for Federal Assistance Programs, discretionary
Federal grants and other forms of financial assistance programs. Applicants for this Federal
assistance program must submit all required forms in the SF-424 Family of forms, including SF424B (Assurances of Non construction Programs) or SF424D (Assurances for Construction
Programs).Applications receiving funds for both non-construction programs and construction
programs must submit both the SF-424B and SF-424D.
By signing the forms in the SF-424 either through electronic submission or in paper copy
submission (for those granted a waiver), the applicant and the signing authorized organization
representative affirm that they have reviewed the certifications and assurances associated with
the application for Federal assistance and (1) are aware the submission of the SF-424 is an
assertion that the relevant certifications and assurances are established and (2) acknowledge that
the truthfulness of the certifications and assurances are material representations upon which
HUD will rely when making an award to the applicant. If it is later determined the signing
authorized organization representative to the application made a false certification or assurance,
caused the submission of a false certification or assurance, or did not have the authority to make
a legally binding commitment for the applicant, the applicant and the individual who signed the
application may be subject to administrative, civil, or criminal action. Additionally, HUD may
terminate the award to the applicant organization or pursue other available remedies. Each
applicant is responsible for including the correct certifications and assurances with its
application submission, including those applicable to all applicants, those applicable only to
Federally recognized Indian tribes, or Alaska native villages and those applicable to applicants
other than federally recognized Indian tribes or Alaska native villages.
Assurances. By submitting your application, you provide assurances that, if selected to receive
an award, you will comply with U.S. statutory and public policy requirements, including, but not
limited to civil rights requirements. Applicants and recipients are required to submit assurances of
compliance with federal civil rights requirements. See, e.g., Title VI of the Civil Rights Act of
1964, Title IX of the Education Amendments Act of 1972, Section 504 of the Rehabilitation Act
of 1973, and the Age Discrimination Act of 1975; see also 24 C.F.R. §§ 1.5; 3.115; 8.50; and
146.25. HUD accepts these assurances in the form of the SF-424B and SF-424D, which also
require compliance with all general federal nondiscrimination requirements in the administration
of the grant.

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V. Application Review Information.
A. Review Criteria.
1. Rating Factors.
1. Rating Factors.
Scope of Review. HUD will review applications in accordance with the requirements of this
NOFO and the Housing Counseling Program. HUD may rely on performance monitoring and
audit reports, financial status information, and other information available to HUD to make score
determinations. The maximum points for each factor are outlined below. Applicants that manage
networks of counseling agencies should not submit a separate response for each proposed
Subgrantee and Branch. Rather, such applicants will be directed to use the Chart A2 Supplement
(Excel).
Unless otherwise specified, the term “Chart A” refers to Chart A1 for LHCA Applicants and to
Chart A2 for Intermediary/SHFA/MSO Applicants. The same convention applies to all charts.
RATINGS FACTOR
POINTS CHART
Rating Factor 1. Capacity of the Applicant
Sub-factor A HECM Average Hours
2
N/A
Sub-factor B Training and Industry Standards
7
Chart A
Sub-factor C Client Satisfaction and Progress
4
Chart A
Rating Factor 2. Need / NOFO Priorities
Sub-factor A Rural Communities
2
N/A
Sub-factor B Vulnerable Populations: Fair Housing
2
Chart C
Sub-factor C Vulnerable Populations: Staff Training
2
Chart C
Sub-factor D Vulnerable Populations: Disabilities
2
Chart C
Sub-factor E Vulnerable Populations: Limited English Proficiency 2
Chart C
Sub-Factor F Vulnerable Populations: Mobility Counseling
2
Chart C
Sub-factor G Vulnerable Populations: Lead Paint
1
Chart C
Sub-factor H Emergency Preparedness
2
Chart C
Rating Factor 3. Soundness of Approach
Sub-factor A Clients Served
14
N/A
Sub-factor B Cost per Client
6
Chart E
Sub-factor C Counseling Expense Ratio
3
Chart E
Sub-factor D Grant to Total Program Expenses Ratio
5
Chart E
Sub-factor E Allocation to Subgrantees
2
Chart A
Sub-factor F Counseling and Education Services
4
N/A
Sub-factor G Modes of Providing Services
8
Chart A
Sub-factor H Oversight Activities
6
Chart D
Rating Factor 4. Leveraging Resources
Sub-factor A Itemized Leveraging
4
Chart B
Rating Factor 5. Achieving Results and Program Evaluation
Sub-factor A Performance and HCS Reporting
8
N/A
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Sub-factor B Grant Expenditure History
Sub-factor C Counseling Outcomes
Preference Points (maximum of 2 points total)
Option 1
Opportunity Zones
Option 2 Promise Zones
Option 3 HBCU

4
8

N/A
N/A

2
2
2

Chart A
Chart A
Chart A

Rating Factors. The maximum points available are outlined below. The total available is 102
points. HUD reminds applicants that responses are subject to verification.
Rating Factor 1: Capacity of the Applicant

Maximum Points: 13

(a) Duration of HECM Counseling Session (2 points). Agencies with HECM Roster
counselors will be assessed on the average duration of a counseling session. HUD will use its
own records to score this factor.
(b) Counselor Training and Industry Standards (7 points). Using Chart A, indicate by
entering an “x” in the appropriate field if:
- Agencies have counselors on staff that have received formal housing counseling training in
the past two years, not including on-the-job training (Field I)
- Agencies have counselors on staff who have passed the HUD Housing Counseling
Certification Exam (Field J)
- Agencies adopted the National Industry Standards for Homeownership Education and
Counseling (http://homeownershipstandards.com) prior to the NOFO application submission
date (Field K)
Intermediaries, SHFAs, and MSOs must specify this information for each Branch or Subgrantee
on the Supplemental Chart A2 Attachment (Excel), and then transfer the totals onto Chart A2.
In addition, Applicants that manage networks of counseling agencies and also provide housing
counseling services at their main office must include this office in the list of Subgrantees and
Branches. The main office will be treated as a Branch for scoring and funding formula purposes.
When completing Chart A2, Applicants must only list offices that provide housing counseling
services to a minimum of thirty clients per year. (This requirement does not apply to agencies
that offer only reverse mortgage counseling.)
(c) Client Satisfaction and Progress (4 points). Scoring of this sub-factor will reward
Applicants that measure customer satisfaction and progress. On Chart A, indicate if the
Agency:
- Issued client exit surveys at the end of counseling or education sessions (Field L)
- Issued follow-up client surveys after the counseling was completed (Field M)
- Pulled credit reports as part of housing counseling follow-up prior to the termination of
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counseling (Field N)
Intermediaries, SHFAs, and MSOs must specify this information for each Branch/Subgrantee
on the Chart A2 Supplement (Excel), and then transfer the totals onto Chart A2.
Rating Factor 2: Need / NOFO Priorities

Maximum Points: 15

(a) Rural Communities (2 points). HUD will use agency-reported data to determine the extent
that an Applicant (and, if applicable, its network) serves rural clientele, as defined by the U.S.
Department of Agriculture (USDA) at 7 C.F.R. § 3550.10.
(b) Affirmatively Furthering Fair Housing (2 points). Applicants must affirmatively further
fair housing in their use of grant funds, per Section 808(e)(5) of the Fair Housing Act. Each
recipient, consistent with HUD's AFFH regulations at 24 CFR §§ 5.151 and 5.152, is required to
submit a certification that it will affirmatively further fair housing. Applicants must provide a
brief description of any meaningful action the Applicant will take that is consistent with the
obligation to AFFH. (Chart C, Field A).
(c) Staff Training (2 points). Applicants must describe how they will train their staff on fair
housing issues, including promoting housing that is affordable, safe, decent, free of unlawful
discrimination, and accessible as required under fair housing and civil rights laws (Chart C,
Field B).
(d) Persons with Disabilities (2 points). Applicants must describe how access to programs and
activities are readily accessible to and usable by persons with disabilities. Applicants must also
describe what appropriate steps are taken to ensure effective communication with persons with
disabilities and identify their policies and procedures for providing reasonable accommodations
(Chart C, Field C).
(e) Persons with Limited English Proficiency (2 points). Applicants must describe how they
take reasonable steps to ensure persons with limited English proficiency (LEP) have meaningful
access to the program and activities (Chart C, Field D).
(f) Mobility Counseling (2 points). Applicants must describe how they provide
mobility counseling (Chart C, Field E).
(g) Lead-Based Paint (1 point). Applicants must describe how they inform clients about the
hazards of lead-based paint in homes (Chart C, Field F).
(h) Emergency Preparedness (2 points). Applicants must describe their emergency
preparedness and/or disaster recovery activities (Chart C, Field G and H).
Rating Factor 3: Soundness of Approach / Scope of
Housing Counseling Services

Maximum Points: 48

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(a) Clients Served (14 points). HUD will evaluate the total number of clients served by the
Applicant as reported in its HUD-9902 for Fiscal Year 2020. Applicants who were approved
after September 30, 2020 and therefore were not required to submit a form HUD-9902 covering
this period must prepare and submit a Form HUD-9902 as part of the application (See Section
IV.B Content and Form of Application Submission for more details). Such agencies must
ensure that their HUD-9902 data reflects the entire fiscal year, and not just that portion for
which the agency was HUD-approved.
(b) Cost Per Client (6 points). HUD will evaluate the Applicant’s Housing Counseling
Program actual expenses for the period October 1, 2019, through September 30, 2020, which
includes salaries and fringe of housing counselors and staff who provide counseling or group
sessions, other direct costs, and indirect costs. Applicants must document their total housing
counseling program expenses in Chart E. MSOs, SHFAs, and Intermediaries must include total
expenses for their entire proposed network.
Agencies that became HUD-approved during the past year should ensure their expenses reflect
the entire fiscal year 2020, and not just that portion for which the agency was HUD-approved.
(c) Counseling and Education Expense Ratio (3 points). HUD will calculate the ratio of
counseling and education costs to total program expenses (Chart E).
(d) Ratio of HUD Grant to Total Program Expenses (5 points). HUD will calculate the ratio
of an Applicant’s previous HUD grant to its total Housing Counseling Program expenses (Chart
E). Applicants without a previous HUD grant will be awarded full points.
(e) Allocation to Subgrantees (2 points). Intermediaries, SHFAs, and MSOs must indicate the
percentage of the proposed award the Applicant intends to allocate to itself (Chart A2, Field P1)
and to each Subgrantee and Branch (Chart A2, Field P2). Points are awarded to Applicants who
sub-allocate a larger percentage of their award.
(f) Services Provided (4 points). HUD will consider the types of housing counseling
and education services offered. HUD will use its own records to score this factor.
(g) Methods of Service Delivery Provided (8 points). HUD permits housing counseling
agencies to provide various modes of counseling and education that reach a broader range of
clients who would not otherwise receive housing counseling services. Applicants must indicate
their methods of service provision in (Chart A, Fields S-V).
(h) Oversight Activities (6 points). Applicants must indicate their oversight and quality
control activities (Chart D). Items selected in these charts must be included in an agency's
quality control plan and may be verified by HUD staff prior to approving grant progress reports
and drawdown requests, as well as during performance reviews.
Rating Factor 4: Leveraging Resources
Maximum Points: 4
HUD’s CHC grants should not be the sole source of funds for a Housing Counseling Program.
Grantees are expected to seek other sources of funding, both private and public, to supplement
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HUD grant funding. This rating factor will assess an Applicant’s financial capacity per 24
CFR § 214.303(i) and is not tied to a voluntary or required cost-share assessment. HUD will
calculate the ratio of an Applicant’s anticipated HUD grant to its total qualified leveraged
funding.
Applicants are evaluated based on the extent to which they have obtained non-federal resources
including direct financial assistance (grants), fees, program income, and in-kind contributions
for the period of performance. Only include funds allocated for the CHC Program. Leveraging
resources cannot consist of federal funds, directly or indirectly. Federal funds that are passed
through state and local governments are ineligible.
Evidence that leveraged funds were actually provided may be reviewed by HUD staff as a part
of the performance reviews.
Applicants must list their leveraged resources in Chart B: Leveraged Resources (Excel) and
complete all fields for each resource.
- In Field A, enter the name of the Applicant, Subgrantee, or Branch (not applicable to
LHCAs). - In Field B, enter the name of the organization providing the resources, including the
point of contact who can verify that these resources are dedicated.
- In Field C, enter the type of contribution.
- In Field D, enter the use of the leveraged funds. For in-kind contributions, describe the goods
or services contributed.
- In Field E, enter the amount of funds from this resource.
Include only funds that will be available during the period of performance. If Applicant’s
funding is available outside of the grant period, the Applicant must pro-rate the funding to
reflect the amount that is available during the grant period. For example, if funds are only
available for three months, then only include 25% of the total amount. Funds available for
multiple years must also be pro-rated (e.g., $100,000 leverage available January 1, 2020
through December 31, 2021, only $37,500 should be entered on Chart B for the 9 months
of April 1, 2021 through December 31, 2021).
While agencies are strongly encouraged to leverage funds from other private and public
sources, they are permitted to charge fees to counseling recipients (See 24 CFR Part 214 for
more information). Agencies are not permitted to charge fees for default counseling or
homeless counseling. In order to receive credit for the fee income, it must be identified as
program income on line “18. Estimated Funding, f. Program Income” of SF-424 as well as in
Chart B: Leveraged Resources (Excel). Program income will be treated using the addition
method (2 CFR 200.307(e)(2)).
Rating Factor 5: Achieving Results

Maximum Points: 20

(a) Performance and HCS Reporting (8 points).
 HUD will evaluate Applicant compliance with programmatic requirements and
oversight results. HUD will use its own records to score this factor.
 Applicants will be assessed on timely validation of their agency profile in HCS, timely
submission of form HUD-9902 reports, and use of their CMS to submit form HUD9902 reports. HUD will use its own records to score this factor.
(b) Grant Expenditure History (4 points). HUD will evaluate the Applicant's use of
previously awarded grant funds. Significant delays in grant execution and expenditure,
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including the need to recapture funding, will be taken into consideration. HUD will use its own
records to score this factor. Applicants without a previous HUD grant will be awarded full
points.
(c) Counseling Outcomes (8 points). HUD will evaluate the positive impacts that an
Applicant’s housing counseling services had on clients. HUD will use its own records to score
this factor.
2. Other Factors.
This program does not offer points for Section 3.
Preference Points
HUD encourages activities in support of the Secretary's Initiatives. HUD may award no more
than two (2) points for any of the three (3) preferences (OZ, PZ or HBCU). Each preference is
worth two points and only one preference can apply to any situation, meaning that applicants will
ONLY be awarded 2 points for being within an OZ, PZ or involving HBCUs.
Opportunity Zones.
Opportunity Zone (OZ) Certification: HUD encourages activities in Opportunity Zones. To
receive two (2) points for this preference, applicants proposing projects in an Opportunity Zone
community must submit the Certification for Opportunity Zone Preference Points (HUD-2996)
that identifies the state, county and census tract(s) of the opportunity zone(s) in which the
activity will be carried out. To view the list of designated Opportunity Zones, please see the
following link on the U.S. Department of the Treasury website:
https://opportunityzones.hud.gov/
Applicants who do not complete this form and submit it along with the rest of their application
package will not be eligible to receive the points. Additionally, applicants who do complete and
submit this form, but indicate they intend to use less than 50% of the award within Opportunity
Zone tracts, will also be ineligible to receive preference points, unless: a.) the applicant can show
why they are unable to expend at least 50% of the grant award within Opportunity Zone
designated tracts, or b.) the applicant is able to make a compelling case for why the amount that
will be expended will have a significant impact within Opportunity Zone designated tracts. Click
here to view HUD’s Opportunity Zones webpage.
To receive these OZ preference points, investment and activities must be located in an OZ.
Intermediaries, SHFAs, and MSOs will be assessed based on the location of their Subgrantees
and Branches. HUD will use the list of designated OZs as it exists at the application due date. To
qualify for these two preference points, you must list your agency’s 11-digit census tract number
in Chart A, Field O1. Do not list census tracts for Branches or Sub-grantees that are not located
in OZs.
Successful applicants who receive these Opportunity Zone preference points must commit to
expending the estimated percentage of their award in OZ census tracts, as certified in the
Certification for Opportunity Zone Preference Points.
HBCU.
Page 32 of 43

An applicant partnering with a Historically Black College or University (HBCU) will receive up
to two (2) Preference Points when the application includes a Letter of Commitment certifying
that an HBCU Partnership is in place and signed by an authorizing official of the HBCU and
documentation of the college or university's status as an HBCU. Click here to view the list of
accredited HBCU’s
Promise Zones
HUD encourages activities in Promise Zones (PZ). To receive Promise Zones Preference Points,
applicants must submit form HUD-50153, “Certification of Consistency with Promise Zone
Goals and Implementation,” signed by the Promise Zone Official authorized to certify the project
meets the criteria to receive preference points. To view the list of designated Promise Zones and
persons authorized to certify, please see the Promise Zone pages on HUD’s website.
B. Review and Selection Process.
1. Past Performance
In evaluating applications for funding, HUD will consider an applicant’s past performance in
managing funds. Items HUD will consider include, but are not limited to:
The ability to account for funds in compliance with applicable reporting and recordkeeping
requirements;
Timely use of funds received from HUD;
Timely submission and quality of reports submitted to HUD;
Meeting program requirements;
Meeting performance targets as established in the grant agreement;
The applicant's organizational capacity, including staffing structures and capabilities;
Timely completion of activities and receipt and expenditure of promised matching or leveraged
funds;
The number of persons served or targeted for assistance;
Producing positive outcomes and results.
HUD may reduce scores based on the past performance review, as specified under V.A. Review
Criteria. Whenever possible, HUD will obtain past performance information. If this review
results in an adverse finding related to integrity of performance, HUD reserves the right to take
any of the remedies provided in Section III E., Statutory and Regulatory Requirements Affecting
Eligibility, "Pre-selection Review of Performance" document link above.
2. Assessing Applicant Risk.
In evaluating risks posed by applicants, HUD may use a risk-based approach and may consider
any items such as the following:



Financial stability;
Quality of management systems and ability to meet the management standards prescribed
in this part;

Page 33 of 43






History of performance. The applicant's record in managing Federal awards, if it is a
prior recipient of Federal awards, including timeliness of compliance with applicable
reporting requirements, failing to make significant progress in a timely manner, failing to
meet planned activities in a timely manner, conformance to the terms and conditions of
previous Federal awards, and if applicable, the extent to which any previously awarded
amounts will be expended prior to future awards;
Reports and findings from audits performed under Subpart F—Audit Requirements of
this part or the reports and findings of any other available audits; and
The applicant's ability to effectively implement statutory, regulatory, or other
requirements imposed on non-Federal entities.

3. Review and Selection Process.
Technical Review. First, a technical sufficiency review will determine whether each
application meets the threshold requirements set forth in this NOFO and whether all required
forms have been properly submitted. Section IV.D.4 provides the procedures to correct a
deficient application.
General Review. The second review will evaluate the responses to each Rating Factor outlined
above and other relevant information. Applications will be evaluated competitively and ranked
against other Applicants that applied in the same funding category.
Minimum Fundable Score. All applications will be scored on a 102-point scale, including
preference points, as outlined in Section V.A of this NOFO. For FY21, HUD anticipates making
awards to all Applicants scoring 75 points or greater from this section. To be eligible for any
funding under the NOFO, Applicants must meet the minimum fundable score. If available funds
are insufficient to provide grants to all Applicants achieving the minimum fundable score, grants
will be awarded in rank order until all available funds have been distributed. HUD reserves the
right to adjust the minimum fundable score.
Funding Methodology. This methodology awards grantees a base award determined by the size
and nature of their counseling networks. The methodology then augments that amount based on
performance within HUD’s CHC Program and other relevant criteria.
Applicants may also indicate a maximum grant request (Chart A, Field Q) that will be
considered as a cap in establishing the maximum CHC award. Separately, Applicants applying
for the HBCUs, Tribal Colleges and Universities, and other MSIs initiative must indicate their
desired award amount on Chart F.
Although HUD will determine the total award amount for each Applicant, Grantees themselves
will determine the actual funding amounts to be distributed to Subgrantees and/or Branches.
(a) Base Award. The funding methodology provides a Base Award for successful Applicants.

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1. LHCAs applying independently are not eligible to manage a network of subgrantees.
While LHCAs applying independently may sub-allocate HUD grant funds to their Branch
offices, the funding formula will not augment the award for such offices.
2. For Intermediaries, SHFAs, and MSOs that provide subgrants or fund their own
Branches, the award will be calculated based on the size of the Applicant’s funded
network. In the Chart A2 Supplement (Excel), Applicants must list and describe their
funded network. If the entity is a Branch of the Applicant’s organization, place an “X” in
Field D. If the entity is a Subgrantee, place an “X” in Field E. For each member of the
Applicant's funded network, there should be one and only one box checked (i.e. either
Field D or Field E, not both). If an Intermediary, SHFA, or MSO provides counseling
services at their main office, Applicants should list their main office as a Branch.
Subgrantees and Branches that did not provide housing counseling services to a minimum of
thirty clients in the previous year must not be listed. Branches that are part of a Subgrantee’s
organization must not be listed. Awards may be adjusted based on an Applicant’s funded
network.
(b) Competitive Funding Amount. Higher scoring submissions may receive incentive
funding on top of the base funding.
(c) Funding to Monitor a Network. HUD may augment the award for oversight and quality
control activities. HUD may base a portion of this calculation on an Applicant's plan to review
members of its funded network using form HUD-9910 and to share results and follow-up
actions with HUD (Chart D2, Field 1). Chart D2 includes a space for Applicants to indicate the
number of funded Subgrantees and Branches that they propose to review during the upcoming
performance period. The bonus will be capped at the lesser of: a) five reviews, or b) 50% or less
of the Applicant’s funded network.
(d) Number of Counselor FTEs. HUD may augment the award based on the number of
Housing Counselor Full-Time Equivalents (FTEs) that provide housing counseling services as of
September 30, 2020 (Chart A, Field F). Applicants that provide counseling services at their main
office may count the number of housing counselor FTEs at the main office in addition to the
offices of Subgrantees and/or Branches.
(e) Funding of Reverse Mortgage Counseling. HUD may augment the award based on the
number of HECM Roster Counselors that provide housing counseling services as of
September 30, 2020 (Chart A, Field G).
(f) Funding of Default Counseling for Reverse Mortgages. HUD may augment the award
based on an Applicant’s commitment to providing HECM default counseling. Applicants are
asked to indicate how many of their counselors will provide default counseling for reverse
mortgage borrowers from April 1, 2021 to September 30, 2022 (Chart A, Field H). The
bonus will be capped at five such counselors per Agency, Branch, and Subgrantee. As a
reminder, default counseling for reverse mortgages can be provided by non-HUD HECM
Roster Counselors.
By the end of the period of performance, such counselors should have:
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1. Attended at least eight hours of training in reverse mortgages in the three years prior
to the end of the grant period; and
2. Provided services to a minimum of ten HECM default counseling clients during the
grant period.
Grantees must provide documentation supporting these activities in grant activity reports.
Funds Recapture. HUD may decrease the award amount if changes to the network size, number
of housing counselor FTEs, or services provided would result in a lower amount than was
awarded and reserves the right to recapture all or part of the resulting grant. Additionally, HUD
may recapture funds unspent in the time allotted.
Mergers, Acquisitions, and Other Changes in Organizational Structure. Anticipated
mergers, acquisitions, or other changes in Grantee(s) legal or organizational structure must be
reported to Grantee’s Point of Contact in HUD’s Office of Housing Counseling within 15 days
of implementation of such changes. However, HUD encourages grantees to report such changes
as early as possible to ensure that the organization remains eligible for grant funds. In the case of
a simple name change, HUD may make the award in the name of the newly named entity. In the
case of a merger, the new or merged entity may be eligible to receive grant funding made to the
original Grantee(s), provided they meet certain conditions, including but not necessarily limited
to:
1. The new or merged entity receives HUD approval as a housing counseling agency and
demonstrates in its application that it meets all eligibility requirements for a HUDapproved housing counseling agency in Section 106, 24 CFR part 214, and HUD
Handbook 7610.1, including oversight and reporting, housing counseling experience
and staffing
2. The newly named entity has a DUNS Number, has registered in SAM and has passed the
IRS check conducted as part of the SAM registration process;
3. The Name Check review process has been conducted for the proposed new awardee;
4. An amendment to the award agreement assigning the award to the new entity is
completed; and
5. A new LOCCS access form has been filed with the HUD Accounting Office.
4. Historically Black Colleges and Universities, Tribal Colleges and Universities, and other
Minority Serving Institutions.
Purpose: The purpose of this initiative is to expand opportunities for wealth building and
financial stability in underserved minority communities, by increasing access to safe affordable
housing, financial education, and homeownership. Historically Black Colleges and Universities
(HBCU), Tribal Colleges and Universities, and other Minority Serving Institutions (MSI) have
strong relationships with stakeholder communities and have a vested interest in improving socioeconomic outcomes for minorities. Specifically, this initiative is designed to expand these
institutions’ roles and effectiveness in addressing the needs of their local communities, expand
partnerships with housing counseling agencies, and provide housing counseling services. HUD
seeks to leverage expert experience and social position of MSIs within minority communities to
help remove any barriers to housing services and increase financial education for this targeted
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population.
Eligible Applicants: Applicants requesting funds dedicated for HBCUs and other MSIs (and
partnerships therewith) must submit proof of the college or university’s status as an HBCU or
MSI. Additionally, Applicants that are partnering with an HBCU or MSI must submit a letter
certifying that an HBCU or other MSI partnership is in place or that there is an intent to enter a
partnership. The letter must be signed by the Applicant and an authorizing official of the HBCU
or other MSI and the Applicant must provide documentation of the partnering college or
university's status as an HBCU or other MSI.
When executing the grant, you must submit a Memorandum of Understanding (MOU) or similar
agreement signed by all partners to signify their formal commitment. The MOU should at least
clearly specify the partnership’s purpose and activities; each organization’s role and
responsibilities for funding, participation, management and organizational structure, and
compliance; and integrating data sharing or reporting capabilities.
Eligible Activities: The eligible activities are outlined in Section IV.F, Funding Restrictions.
Maximum Award Amounts. Eligible Applicants must indicate a maximum grant request that
will be considered as a cap in establishing the maximum award. An eligible Applicant can request
up to $250,000 as an HBCU or other MSI, or for its partnership and/or its subgrantee partnership
with an HBCU or other MSI. The Applicant may also request up to $150,000 for each additional
partnership and/or its subgrantee partnership with an HBCU or other MSI. HUD will use the
NOFO score; narrative response on the Form HUD-9906, Chart F; and other factors to rate and
rank applications. Depending on factors such as the number of eligible Applicants and other
factors, HUD reserves the right to fund less than the amount requested in the application.
Review and Selection Process. Eligible Applicants interested in this funding must complete the
following information on Form HUD-9906, Chart F.
1. Number of Clients Served. How many housing counseling clients the Applicant or the
Applicant’s network of HBCUs or other MSIs partners plan to serve with the funding.
2. Award Amount (Budget). Provide the total amount of funds requested for these
purposes, and if applicable, indicate the amount allocated to each partnership.
3. Statement of Work. Applicants must describe the following.
a. All proposed eligible activities and major tasks required to successfully implement
the proposed initiative.
b. The extent to which there is a need to fund the proposed initiative and the importance
of meeting the need(s).
c. The relevant experience and capacity of the Applicant, its staff, and HBCU or other
MSI partners in implementing the proposed eligible activities.
d. How the Applicant will measure the outcomes on the target population by the end of
the grant performance period.
e. How the Applicant proposes to integrate the institution’s students and faculty into
proposed eligible activities.

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f. How the community (e.g., businesses, residents, and others) will be involved in the
implementation of the program and how the institution will expand its role in the
target community.
g. The other resources (not including HUD’s CHC Grant) that support or fund the
Applicant’s existing housing counseling related partnerships with HBCUs or other
MSIs. Include the dollar amounts of support provided, if applicable.
VI. Award Administration Information.
A. Award Notices.
Following the evaluation process, HUD will notify successful applicants of their selection for
funding. HUD will also notify other applicants, whose applications were received by the
deadline, but have not been chosen for award. Notifications will be sent by email to the
person listed as the AOR in item 21 of the SF424.
Negotiation. After HUD has made selections, HUD will negotiate specific terms of the funding
agreement and budget with selected applicants. If HUD and a selected applicant do not
successfully conclude negotiations in a timely manner, or a selected applicant fails to provide
requested information, an award will not be made to that applicant. In this case, HUD may
select another eligible applicant.
HUD may impose special conditions on an award as provided under 2 CFR 200.208:
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Based on HUD’s review of the applicant’s risk under 2 CFR 200.206;
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When the applicant or recipient has a history of failure to comply with the general or
specific terms and conditions of a Federal award;
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When the applicant or recipient fails to meet expected performance goals contained in a
Federal award; or
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When the applicant or recipient is not otherwise responsible.
Adjustments to Funding. To ensure the fair distribution of funds and enable the purposes
or requirements of a specific program to be met, HUD reserves the right to fund less than
the amount requested in an application.
a. HUD will fund no portion of an application that:
(1) Is not eligible for funding under applicable statutory or regulatory requirements;
(2) Does not meet the requirements of this notice; or
(3) Duplicates other funded programs or activities from prior year awards or other
selected applicants.
b.If funds are available after funding the highest-ranking application, HUD may fund all or part
of another eligible fundable application. If an applicant turns down an award offer, or if HUD
and an applicant do not successfully complete grant negotiations, HUD may withdraw the
award offer and make an offer of funding to another eligible application.
c. If funds remain after all selections have been made, remaining funds may be made
available within the current FY for other competitions within the program area, or be held for
future competitions, or be used as otherwise provided by authorizing statute or appropriation.
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d. If, after announcement of awards made under the current NOFO, additional funds become
available either through the current appropriations, a supplemental appropriation, other
appropriations or recapture of funds, HUD may use the additional funds to provide additional
funding to an applicant awarded less than the requested amount of funds to make the full award,
and/or to fund additional applicants that were eligible to receive an award but for which there
were no funds available.
Funding Errors. If HUD commits an error that when corrected would cause selection of an
applicant during the funding round of a Program NOFO, HUD may select that applicant for
funding, subject to the availability of funds. If funding is not available to award in the current
fiscal year, HUD may make an award to this applicant during the next fiscal year, if funding is
available then.
B. Statutory and Administrative, National and Department Requirements for HUD
Recipients
For this NOFO, the following Administrative, National and Department Policy Requirements
and Terms for HUD Financial Assistance Awards apply. (Please select the linked text to read the
detailed description of each applicable requirement).
1. Unless otherwise specified, these non-discrimination and equal opportunity authorities and
other requirements apply to all NOFOs. Please read the following requirements carefully as the
requirements are different among HUD's programs.
Compliance with 24 CFR part 50 or 58 procedures is explained below:
In accordance with 24 CFR 50.19(b)(2), (3), (4), (9), (12), and (13), activities funded under this
NOFO are exempt or categorically excluded from environmental review under the National
Environmental Policy Act of 1969 (42 U.S.C. 4321) and not subject to environmental review
under related laws and authorities.
2 CFR 200.340 Termination
2 CFR 200.216 Prohibition on Certain Telecommunication and Video Surveillance Services or
Equipment
Lead Based Paint Requirements.
When providing education or counseling on buying or renting housing that may include pre1978 housing under your grant you must inform clients of their rights under the Lead Disclosure
Rule (24 CFR part 35, subpart A), and, if the focus of the education or counseling is on rental or
purchase of HUD-assisted pre-1978 housing, the Lead Safe Housing Rule (subparts B, R, and, as
applicable, F - M).
C. Reporting.
HUD requires recipients to submit performance and financial reports under OMB guidance and
program instructions.
1. Recipient Integrity and Performance Matters. Applicants should be aware that if the total
Federal share of your Federal award includes more than $ 500,000 over the period of
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performance, you may be subject to post award reporting requirements reflected in Appendix XII
to Part 200-Award Term and Condition for Recipient Integrity and Performance Matters. 2.
Race, Ethnicity and Other Data Reporting. HUD requires recipients that provide HUDfunded program benefits to individuals or families to report data on the race, color, religion, sex,
national origin, age, disability, and family characteristics of persons and households who are
applicants for, participants in, or beneficiaries or potential beneficiaries of HUD programs in
order to carry out the Department’s responsibilities under the Fair Housing Act, Executive Order
11063, Title VI of the Civil Rights Act of 1964, and Section 562 of the Housing and Community
Development Act of 1987.
4. Compliance with the Federal Funding Accountability and Transparency Act of 2006
(Pub. L. 109-282) as amended (FFATA). FFATA requires information on Federal awards be
made available to the public via a single, searchable website, which is
www.USASpending.gov. Accordingly, each award HUD makes under this NOFO will be
subject to the requirements provided by the Award Term in Appendix A to 2 CFR Part 170,
“REPORTING SUBAWARD AND EXECUTIVE COMPENSATION INFORMATION,”
unless the Federal funding for the award (including funding that may be added through
amendments) is not expected to equal or exceed $30,000. Requirements under this Award
Term include filing subaward information in the Federal Funding Accountability and
Transparency Act (FFATA) Sub-award Reporting System (FSRS.gov) by the end of the
month following the month in which the recipient awards any sub-grant equal to or greater
than $30,000. Each applicant under this NOFO must have the necessary processes and
systems in place to comply with this Award Term, in the event that they receive an award,
unless an exception applies under 2 CFR 170.110.
5. Program-Specific Reporting Requirements
Grant Activity Report. Grantees must comply with all reporting requirements found in the
grant agreement including but not limited to HUD-9902 reporting, providing itemized costs,
fulfilling commitments made in the NOFO, and submitting final narratives. Grantees receiving
HBCU/other MSI funds will have additional requirements as outlined in the grant agreement.
D. Debriefing.
For a period of at least 120 days, beginning 30 days after the public announcement of awards
under this NOFO, HUD will provide a debriefing related to their application to requesting
applicants. A request for debriefing must be made in writing or by email by the authorized
organization representative whose signature appears on the SF-424 or by his or her successor in
office and be submitted to the POC in Section VII Agency Contact(s), below. Information
provided during a debriefing may include the final score the applicant received for each rating
factor, final evaluator comments for each rating factor, and the final assessment indicating the
basis upon which funding was approved or denied.
The debriefing period will be no more than 150 days after the announcement of awards.
VII. Agency Contact(s).
HUD staff will be available to provide clarification on the content of this NOFO.
Questions regarding specific program requirements for this NOFO should be directed to the POC
listed below.
Name:
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Tracie Oaks
Phone:
Email:
[email protected]
Persons with hearing or speech impairments may access this number via TTY by calling the tollfree Federal Relay Service at 800-877-8339. Please note that HUD staff cannot assist applicants
in preparing their applications.
VIII. Other Information.
1. National Environmental Policy Act.
This NOFO provides funding pursuant to Section 106 as implemented in 24 CFR Part 214,
which does not contain environmental review provisions because activities under these
regulations are excluded from environmental review under the National Environmental Policy
Act of 1969 (42 U.S.C. 4321) ("NEPA"). Accordingly, under 24 CFR 50.19(c)(5), this NOFO is
categorically excluded from environmental review under NEPA.
2. Web Resources.

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Affirmatively Furthering Fair Housing
Code of Conduct list
Assistance Listing (formerly CFDA)
Dun & Bradstreet
Equal Participation of Faith-Based Organizations
Federal Awardee Performance and Integrity Information System
FFATA Subaward Reporting System
Grants.gov
HBCUs
Healthy Homes Strategic Plan
Healthy Housing Reference Manual
HUD’s Strategic Plan
HUD Grants
Limited English Proficiency
NOFO Webcasts
Opportunity Zone
Procurement of Recovered Materials
Promise Zones
Section 3 Business Registry
State Point of Contact List
System for Award Management (SAM)
Uniform Relocation Assistance and Real Property Acquisition Act of 1970 (URA)
USA Spending

3. Program Relevant Web Resources

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APPENDIX
Appendix A
Definitions
1. Affiliate. See definition at 24 CFR 214.3.
2. Applicant. A HUD-approved housing counseling agency or SHFA, MSO or local
government applying for a CHC grant from HUD through this NOFO. The term
Applicant includes the agency's branches identified in its application.
3. Branch. See definition at 24 CFR 214.3.
4. Continuity of Operations Plan (COOP). An organization’s internal efforts to ensure
that a viable capability exists to continue essential functions across a wide range of
potential emergencies. COOP plans and procedures delineate essential functions, specify
succession to office and the emergency delegation of authority, provide for the
safekeeping of vital records and databases, identify alternate operating facilities, and
provide for interoperable
communications.
5. Counseling. See definition at 24 CFR 214.3.
6. Education. See definition at 24 CFR 214.3.
7. Final Compliance Date. The date, determined by HUD, when all housing counseling
required by or provided in connection with any HUD program must be performed by a
HUD certified housing counselor and all group education must be overseen by a HUD
certified housing counselor. See 24 CFR 214.103(n).
8. Full-time equivalent. The number of total hours worked divided by the maximum
number of compensable hours in a full-time schedule as defined by law. For example, if
the normal schedule for a quarter is defined as 411.25 hours ([35 hours per week * 52
weeks per year 5 weeks regulatory vacation)] / 4), then someone working 100 hours
during that a quarter represents 100/411.25 = 0.24 FTE. Two employees working in total
400 hours during that same quarterly period represent 0.97 FTE.
9. Grantee. A HUD-approved housing counseling agency or SHFA that receives housing
counseling funds from HUD through this NOFO. The term Grantee includes the
Grantee's branches identified in its application.
10.
Historically Black College and University (HBCU). Any historically black
college or university that was established prior to 1964, whose principal mission was, and
is, the education of black Americans, and that is accredited by a nationally recognized
accrediting agency or association determined by the Secretary of Education to be a
reliable authority as to the quality of training offered or is, according to such an agency
or association, making reasonable progress toward accreditation.
11.
Homeownership Counseling. See definition at 24 CFR 5.100.
12.
HUD HECM Roster Counselor. A housing counselor that has met the
requirements pertaining to HUD's HECM Counseling Standardization and Roster (24
C.F.R. 206, Subpart E) and appears on the HUD HECM Counselor Roster.
13.
Intermediary. See definition at 24 CFR 214.3.
14.
Local Housing Counseling Agency (LHCA). A housing counseling agency that
directly provides housing counseling services. An LHCA may have a main office, and
one or more branch offices, in no more than two contiguous states.
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15. Minority Serving Institution (MSI). An institution serving a high proportion of
minority students. ‘Minority students’ refers to students who are Black,
Hispanic, Asian/Pacific Islander, or American Indian/Alaska Native.
16. Multi-State Organization (MSO). See definition at 24 CFR 214.3.
17. Participating Agency. See definition at 24 CFR 214.3.
18. State Housing Finance Agency (SHFA). See definition at 24 CFR 214.3.
19. Subgrantee. See definition at 24 CFR 214.3.
20. Reverse Mortgage. See definition at 24 CFR 214.3.

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