Updated:Initial Observations on Oregon Hardest Hit Plan Submitted to Treasury.

 Update: I knew I forgot something; added is observation 9 that Oregon did not include any request for funding of legal services in their proposal.

Some initial observations from my first read of the Oregon Hardest Hit proposal:

1. $10 million (13.2% ) of the $76 available for programs (after counseling and admin fees are subtracted from the $88 million) is to be reserved for a two county Deschutes/Jackson) Loan Refinancing Assistance pilot to purchase loans outright via a third party. These two counties represent 9.4% of the state population and the 330 homes expected to be acquired would represent 5.2% of the total of 6,300 homeowners that OHCS expects to help.[If the projected per unit cost of $30,303 is lower than the actual cost, the number of homes acquired would be reduced and the share of all households helped by this program would be decreased].
2. No maximum per household limit for any combination of programs is shown.
3. 120% of STATEWIDE median income continues to the income eligibility limit.
4. For at least one program, the Mortgage Subsidy program, lender forbearance (NOT forgiveness) would count as a 1 for 1 match. New Treasury guidelines HERE (for Home Affordable Unemployment Program (UP)) REQUIRE 3 month forbearance (under certain circumstances) of non GSE loans starting July 1, so hopefully the only forbearance that will be treated as "match" will be forbearance that exceeds minimum already REQUIRED periods.
5. OHCS has carved out an exception of ANY lender match requirement for any HH program, if the loan is one of their Oregon Bond program loans. (Breakouts of Oregon Bond loans receiving HH benefits should be a required reporting element for the HH program).
6. My count is that Oregon projects hiring a total of 53 full time equivalents over a 3 year period, that's 17+ staff yearly for 3 years. Average OHCS FTE personal cost is more than $79,000 [this includes fringes + salaries].
7. Guidelines for the Mortgage Payment Subsidy or Loan Preservation Assistance programs do NOT require that loan modifications reduce borrower front ratio housing expenses to 31% or below (HAMP loan mods DO have that requirement).
8. The PDF package does NOT include the Articles of Incorporation or the Bylaws for the yet to be formed non profit, the Oregon Homeownership Stabilization Initiative. The schedule calls for the completion of non profit formation by August 1 while the expectation has been that Treasury would approve the OHCS plan by July 15th. It seems clear that Treasury will want to review the bylaws, organization, and governance of the non profit AND that therefore these materials must be submitted to Treasury soon.  [I will follow up with OHCS and ask for clarification on timing and process for forming the non profit]. 
9. Oregon did not request or add any line item in their budget for legal services for residents facing foreclosure. (Other Hardest Hit states continue to push this issue with Treasury).

Originally created and posted on the Oregon Housing Blog.