Emergency Justification Memo - Title VI

DEPARTMENT OF THE TREASURY
WASHINGTON, D.C. 20220

TO:

Alex Goodenough, Office of Information and Regulatory Affairs

FROM:

Ryan Law, Deputy Assistant Secretary
Office of Privacy, Transparency, and Records

SUBJECT:

Justification for Homeowner Assistance Fund Program

Pursuant to the Office of Management and Budget (OMB) procedures established at 5 C.F.R. §
1320.13, the Department of the Treasury (Treasury) requests emergency processing for the
Homeowner Assistance Fund information collection request.
On March 11, 2021, the President signed the American Rescue Plan Act of 2021 (the “Act”),
Pub. L. No. 117-2. Title III, Subtitle B, Section 3206 of the Act established the Homeowner
Assistance Fund and provides $9.961 billion for the U.S. Department of the Treasury (Treasury)
to make payments to States (defined to include the District of Columbia, Puerto Rico, U.S.
Virgin Islands, Guam, Northern Mariana Islands, and American Samoa), Indian tribes or tribally
designated housing entities, as applicable, and the Department of Hawaiian Homelands
(collectively the “eligible entities”) to mitigate financial hardships associated with the
coronavirus pandemic, including for the purposes of preventing homeowner mortgage
delinquencies, defaults, foreclosures, loss of utilities or home energy services, and displacements
of homeowners experiencing financial hardship after January 21, 2020, through qualified
expenses related to mortgages and housing.
Section 3206(c)(1) requires the eligible entities to use the funds for the purpose of preventing
homeowner mortgage delinquencies, defaults, foreclosures, loss of utilities or home energy
services, and displacements of homeowners experiencing financial hardship after January 21,
2020, through qualified expenses related to mortgages and housing. Section 3206(e)(1) provides
that not later than 45 days after March 11, 2021, the Secretary shall pay each eligible entity.
Treasury intends to begin making payments as soon as possible given the urgent need for the
funds being disbursed.
This emergency request is to add the Title VI Assurances which will ensure that entities
receiving financial assistance from Treasury provide the necessary assurances that they will
comply with the requirements of Title VI of the Civil Rights Act of 1964 and Treasury’s Title VI
implementing regulations. Treasury requests emergency processing and OMB approval on
5/26/2021 for the Title VI Assurances.