FAQ I(Q1): What is the Combination NOFO? Is this something new for fiscal year (FY) 2025?

A: The FY 2025 NOFO is comprised of two grant programs, previously published as separate NOFOs: the Comprehensive Housing Counseling (CHC) and the Housing Counseling Training (HCT). Eligible applicants may apply for one or both funding opportunities.

FAQ I(Q2): Will the combined FY 2025 Comprehensive Housing Counseling (CHC) and Housing Counseling Training (HCT) NOFO comprise separate awards?

A: Yes. As in previous years, the Comprehensive Housing Counseling (CHC), and Housing Counseling Training (HCT) grant programs are separate awards. Accordingly, they will come in separate award packages and have unique grant agreements and funding documents.

FAQ I(Q3): How do I determine which forms to complete when applying for the combined FY 2025 Comprehensive Housing Counseling (CHC) and Housing Counseling Training (HCT) NOFO?

A: Applicants should review the instructions specific to each grant program, which are detailed in Section IV of the NOFO (Application Contents and Forms). Applicants may apply for more than one grant program using a single application. HUD will not fund incomplete, ineligible, or non-competitive applications.

FAQ I(Q4): Will the Homeownership Initiative be part of this combined NOFO?

A: Funding for the Homeownership Initiative has been shifted to the Comprehensive Housing Counseling program.

FAQ I(Q5): What happened to the HUD-92910 grant forms that we completed for the Training NOFO during previous years?

A: The two individual grant specific forms, the HUD-9906 (CHC) and HUD-92910 (HCT) are consolidated into one fillable PDF with associated charts for applicant completion in applying for the CHC and HCT programs, including the Minority Serving Institution (MSI) Initiative. This fillable PDF should not be separated but submitted as is, with applicants only completing the portions relevant to their own application. The fillable PDF includes a cover page with further instructions and identifies the pages in the fillable PDF that are relevant to each application award.

FAQ I(Q6): What is the deadline for application submission? Does it apply to all the awards regardless of how many we apply for?

A: The application deadline is 11:59:59 PM Eastern Time on 05/26/2026. This year, the application period is 60 days (instead of 30 days), allowing adequate time to apply to one or more grant programs. The deadline is the same regardless of the number of grant programs for which you are applying. Applications received after the deadline will be considered late, and are therefore ineligible.

FAQ I(Q7): What is the period of performance for the grant programs?

A: The Period of Performance (POP) for each program is 18 months, beginning on 10/01/2025 and ending on 03/31/2027.

FAQ I(Q8): Can we be reimbursed for costs incurred prior to the period of performance?

A: No. There will not be reimbursement of pre-award costs. 

FAQ I(Q9): Am I required to submit my agency’s Code of Conduct with my application?

A: No, the Code of Conduct is not required for the NOFO application. Within 30 days of receipt of an award package, agencies must ensure that their Code of Conduct is either included in HUD’s Code of Conduct e-library or have submitted it to HUD’s Grant Management Office. Additional information can be found here: Code of Conduct for HUD Grant Programs | HUD.gov / U.S. Department of Housing and Urban Development (HUD)

FAQ I(Q10): Are there preference points available for the FY 2025 NOFO?

A: No. There are no preference points available for any of the programs in this NOFO.

FAQ I(Q11): Can I alter the required forms or include the required information in a different way?

A: No. Please complete the application charts and forms as provided. Do not attempt to alter the formats. For instance, do not convert an Excel document to a PDF file (or vice versa) or alter the Excel forms. If you don’t provide the required documents in the correct format, your application is incomplete.

FAQ I(Q12): Can I reuse application forms from a previous NOFO?

A: No. Despite some continuity from year to year, there are changes in the application forms. Accordingly, all applicants are required to use the application forms from the FY 2025 NOFO. If you don’t submit the correct forms, your application is incomplete.

FAQ I(Q13): The SF-424, Field 4 asks for “Applicant Identifier.” What should I enter in this field?

A: Applicants should enter their HCS ID as the Applicant Identifier in Field 4 of the SF-424.

FAQ I(Q14): Explain the funding instruments for each funding opportunity.

A: The CHC program is funded under a grant agreement, while the HCT program uses a cooperative agreement.

FAQ I(Q15): Do I need to inform HUD if our organization has a structural change or merger?

A: Yes. Anticipated organizational changes must be reported to your HUD Point of Contact (POC) at least 60 days in advance of the change. HUD approval needs to be obtained for these changes. For more information, see the Mergers, Acquisitions, and Other Changes in Organizational Structure subsection of Section V.D. Selection Process in the NOFO.

FAQ I(Q16): Can applicants submit a paper application for the FY 2025 Comprehensive Housing Counseling (CHC) and Housing Counseling Training (HCT) NOFO? Or must the application be submitted through Grants.gov?

A: 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 the applicant’s business offices are located). For applicants that cannot submit their applications electronically, HUD must receive the applicant’s waiver request at least 15 days before the application deadline. If HUD waives the requirement, HUD must receive your paper application before the deadline of this NOFO. To request a waiver and receive a paper copy of the application materials, you should contact housing.counseling@hud.gov.

FAQ I(Q17): Will the Office of Housing Counseling offer a combined training on the FY 2025 Comprehensive Housing Counseling (CHC) and Housing Counseling Training (HCT) NOFO?

A: Yes, the Office of Housing Counseling will provide webinar training. This will be announced through Office of Housing Counseling email messages. Click here to sign-up for the Office of Housing Counseling’s mailing list.

FAQ I(Q18): The FY 2025 Comprehensive Housing Counseling (CHC) and Housing Counseling Training (HCT) NOFO states that “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).” How should an applicant provide this information?

A: At the time of application, the applicant must provide a statement describing the audit or investigative work. This statement can be added as an attachment to the application.

FAQ I(Q19): Can branches of HUD-approved agencies apply independently for the FY 2025 Comprehensive Housing Counseling (CHC) and Housing Counseling Training (HCT) NOFO as separate applicants?

A: No, Branches are not allowed to apply for the NOFO. Since Branches are legally part of (i.e., not separately incorporated or organized) the Applicant, they are not independently eligible to apply for the NOFO. Per 24 CFR 214.3, a Branch or Branch Office is defined as "[a]n organizational and subordinate unit of a local housing counseling agency, multi-state organization, regional or national intermediary, or state housing finance agency not separately incorporated or organized, that participates in HUD's Housing Counseling program.” Therefore, they are covered by the applications submitted by the LHCA, MSO, Intermediary, or SHFA. View the NOFO at the HUD Office of Housing Counseling HUD Exchange page.

FAQ I(Q20): There are several questions on the SF-424 and HUD-2880 that ask for a dollar amount. Can you provide guidance on the dollar amounts that should be entered on these required forms for the FY 2025 Comprehensive Housing Counseling (CHC) and Housing Counseling Training (HCT) NOFO?

A: On the SF-424, line 18a, Applicants should enter a response of $1.00. Applicants may also indicate, but are not required to, the maximum grant request on Chart A, Field K of form HUD-9906. This amount, if provided, will also be considered in the funding methodology as a cap for setting the maximum grant amount for that Applicant.

On Form HUD-2880 Applicant/Recipient Disclosure/Update Report, line 4 “Amount of HUD Assistance Requested/Received,” Applicants may enter $1.00. The amount entered on this line will not be used by HUD as a cap in establishing the maximum grant amount for the Applicant. Applicants should not enter the amount received from HUD in prior grants on this line, as this is an “initial report” and not an “update report.” Review the grant application instructions downloaded from www.grants.gov.

On the HUD-2880, regardless of the amount listed in line 4, Applicants that have received, or expect to receive HUD assistance for housing counseling in excess of $200,000 during FY 2025 must select “yes” under question two in “Part I Threshold Determinations,” and complete the rest of the form. See instructions for completing the form HUD-2880, here (pages 2-3).

FAQ I(Q21): On the SF-424, is the Applicant Identifier (line 4) the same number as the Agency ID number in HCS? Also, where can I find the Federal Entity Identifier (line 5a)? Is the Federal Award Identifier (line 5b) our grant number?

A: On the SF-424, applicants will enter their HCS ID as their Applicant Identifier (Line 4). Applicants may leave lines 5a and 5b blank.

FAQ I(Q22): On the SF-424 signature page, should I sign and scan the document to upload it to Grants.gov with the Executive Director’s signature, or is there an electronic signature for the FY 2025 Comprehensive Housing Counseling (CHC) and Housing Counseling Training (HCT) NOFO?

A: Both the SF-424 and HUD-2880 forms allow electronic signatures. The SF-424 and several of the other required forms can be completed as web forms in Grants.gov. Instructions on completing Grants.gov web forms can be found in the grants.gov online user guide.

Additionally, the SF-424 instructions available on Grants.gov indicate that for line 21 of the form, “If the application is submitted via Grants.gov, the signature of the authorized representative and the date signed are completed upon submission.”

The Office of Housing Counseling will also accept SF-424s that have been signed, scanned, and uploaded in PDF format to Grants.gov.

FAQ I(Q23): How do we submit the grant application for the FY 2025 Comprehensive Housing Counseling (CHC) and Housing Counseling Training (HCT) NOFO?

A: Applicants should review the FY 2025 NOFO first. Organizations must submit applications online at Grants.gov. Individuals who will submit grant applications on behalf of an organization must register at Grants.gov and be listed as the Authorized Organization Representative (AOR) in SAM. Grants.gov registration involves several steps and may take a few weeks to complete. Registration instructions are on the Grants.gov website.

Applicants must download both the Application Instructions and the Application Package from Grants.gov. Verify that you are submitting your application for the correct funding opportunity. Applications will only be considered for the competition indicated on the submission.

Validated Grants.gov submissions will receive a confirmation of receipt and an application tracking number. If you do not receive a confirmation and tracking number, your application has not been considered received by Grants.gov. Only completed applications received by Grants.gov on or before the deadline will be considered timely submissions. View the NOFO at the HUD Office of Housing Counseling HUD Exchange page.

FAQ I(Q24): Where can I find instructions on downloading the FY 2025 Comprehensive Housing Counseling (CHC) and Housing Counseling Training (HCT) NOFO grant application from Grants.gov and submitting my application?

A: See the Section entitled “Before You Begin” of the FY 2025 NOFO, which refers you to the Grants.gov Quick Start Guide for Applicants. This section contains information on how to download the application and submit materials.

FAQ I(Q25): I am having an issue with the Grants.gov system. Who can I contact for assistance?

A: Grants.gov offers customer support 24 hours a day, seven days per week, except on Federal holidays. Applicants may call 1-800-518-4726 (toll-free) or send an email to Support@Grants.gov. Individuals who are deaf or hard of hearing, as well as individuals with speech or communication disabilities, can make an accessible telephone call to reach Grants.gov. To learn more about how to make an accessible telephone call please visit https://www.fcc.gov/consumers/guides/telecommunications-relay-service-trs.

FAQ I(Q26): I submitted an application in error on Grants.gov. Can I withdraw my application?

A: There is no way to withdraw a submission once it has been submitted. However, an applicant can submit an updated version of their application on Grants.gov. All updates must be completed before the application deadline. HUD will only review the last application received.

FAQ I(Q27): Are there narrative sections to the FY 2025 Comprehensive Housing Counseling (CHC) and Housing Counseling Training (HCT) NOFO?

A: Yes. Each of the program application forms include narrative sections. Applicants should complete any narratives in the charts and comply with the posted character limits.

See Section IV, Application Contents and Format, of the FY 2025 NOFO for details.

FAQ II(Q1): What do I include in Chart D of the HUD-9906?

A: You will complete your total program expenses in Chart D of the HUD-9906 pdf file. Please note that this is not your proposed budget for the forthcoming CHC Grant Program, nor your previous expenditures for a past CHC Grant Program. Rather, the applicant should include the total cost of operating its housing counseling program during FY 2024.

FAQ II(Q2): In completing HUD-9906, Chart D, do I include the funded network that is part of my current grant application?

A: No. When completing Chart D, applicants should include the total cost of operating the housing counseling program for itself and for its funded network as existed during FY 2024. Due to changes in affiliates, the applicant’s FY 2024 network may differ from the applicant’s FY 2025 network. (HUD obtains information about an applicant’s FY 2025 network through the Chart A Supplement.)

FAQ II(Q3): Could you please tell me more about the new Chart F form that is part of this year’s application?

A: Diversified Funding Resources (Chart F) has been added. Applicants will be evaluated based on their ability to show that they have obtained additional resources for their housing counseling activities for the period October 1, 2024 through September 30, 2025, including direct financial assistance, program income, and in-kind contributions: equipment, office space, labor; etc. Resources must be used for the housing counseling program and may be provided by governmental entities, public or private nonprofit organizations, for-profit private organizations, or other entities committed to providing assistance. None of these additional resources can be federal funds or federal pass-through funds.

FAQ II(Q4): Question 1 in Chart E contains two possible checkboxes. Which one do I select? What if neither is applicable?

A: The MSI Initiative requires either that: a. the applicant has partnered with an MSI, or b. the applicant is an MSI itself. Please select the scenario that applies. If neither situation describes your organization and/or its partnership, you are not eligible for the MSI Initiative and should not check either box.

FAQ II(Q5): In previous years, the application asked us to provide the total number of Certified Housing Counselor full-time equivalents (Field D) and the number of HECM Housing Counselor full-time equivalents (Field E). This year, Field F on Chart A is also asking for the number of new HECM Roster counselors. What is this referring to?

A: HUD may provide funding incentives for grantees that employ counselors who become HECM-certified during the period of performance. To be eligible for this incentive, the counselors must not have been on the HECM counselor roster prior to the start of the period of performance. Interested applicants shall indicate in their application how many new HECM Roster Counselors the applicants propose to add during the FY 2025 Period of Performance.

FAQ II(Q6): “Recent Formal Housing Counseling Training for staff” has been changed to “Housing counseling agency staff have attended a Housing Counseling Training provided by HUD or a Training NOFO grantee within the last two years.” Explain what this change means.

A: OHC makes grants to housing counseling agencies in order to provide training to housing counselors. Recipients of that grant are found here. If one or more of your organization’s housing counselors attended training provided by such grantees, you should check the box in Field G of Chart A. Similarly, if one or more of your organization’s housing counselors attended training provided by HUD, you should check the box in Field G of Chart A.

FAQ II(Q7): What if an applicant does not submit the HUD-9906 Chart A Supplement (Excel) with the CHC grant application?

A: MSO, Intermediary, or SHFA applicants that do not submit the HUD-9906 Chart A Supplement (Excel) will not receive points for rating factors that require the data found in that chart.

FAQ II(Q8): Can I apply to just the MSI Initiative?

A: No. To be considered for MSI Initiative funding, Applicants must meet the minimum fundable score required by the CHC Grant Program and provide a complete response to all questions on the HUD-9906, Chart E. Each response will be weighted as part of the scoring for this sub-factor. Failure to submit a fully completed Chart E may result in ineligibility for the MSI Initiative.

FAQ II(Q9): What documentation is needed to demonstrate eligibility for Applicants partnering with an MSI for funding through the CHC Grant Program’s MSI Initiative?

A: A certifying statement that the Applicant or its partnering MSI appears on the latest Department of Education (DOE) MSI Eligibility Matrix as found here, and a letter of commitment confirming the partnership. The letter must also include the signature of a leadership official at the MSI.

FAQ II(Q10): One of the subgrantees in my proposed network is currently inactive. May I add them to my Chart A Supplement (Excel)?

A: No. Parent organizations must ensure that all subgrantees listed as part of their funded network are active and have their own unique HCS ID at the time of grant application. Subrecipients who are not active or who do not have their own unique HCS ID at the time of their application are not eligible for funding or inclusion in the application.

FAQ II(Q11): One of the subgrantees in my proposed network does not yet have an HCS ID. May I add them to my Chart A Supplement (Excel)?

A: No. Parent organizations must ensure that all subgrantees listed as part of their funded network are active and have their own unique HCS ID at the time of grant application. Subrecipients who are not active or who do not have their own unique HCS ID at the time of their application are not eligible for funding or inclusion in the application.

FAQ II(Q12): What new items are being scored in the FY 2025 Comprehensive Housing Counseling (CHC) Grant Program?

A: Two new questions have been added for scoring:
- “One or more Housing Counseling Program staff have 3 or more years of experience as a HUD certified housing counselor or other program work as an employee of a HUD-approved Housing Counseling agency” in Form HUD-9906 Chart A, Question H.

- “Evidence of client follow-up is maintained in the client file” in Form HUD-9906 Chart A, Question J.

There are new narratives about:

- Providing services in Opportunity Zones (Form HUD-9906 Chart B, Question A)

- Experience Working with HUD-Assisted Renters and Federally Insured Mortgage Programs (Form HUD-9906 Chart B, Question B)

- Emergency Preparedness and Recovery (Form HUD-9906 Chart B, Question C)

A new chart (Chart F) has been added. All applicants must describe their various funding sources (i.e. leveraging). HUD hopes to encourage reliance on other sources of funds.

Additionally, there have been changes to the point allocations to achieve meaningful scoring differences among applicants. For full details on scoring and point allocation, see Section V, Application Review Information, in the grant application package.

FAQ II(Q13): How do we know if a direct cost is eligible under the FY 2025 Comprehensive Housing Counseling (CHC) Grant Program?

A: To be reimbursed under the FY 2025 Comprehensive Housing Counseling (CHC) Grant Program, a cost must be incurred pursuant to an eligible activity. The eligible activities are listed in Section II. Eligibility:
• Housing counseling (See (2)(a)(ii)(A) of this section for limitations.)

• Group education as defined in 24 CFR 214.3 “Education”
• Oversight, compliance, and quality control;
• Supervision of housing counseling staff;
• Housing counselor training and certification; and
• Marketing and outreach of the program

The grantee must be able to justify and document the connection between the direct cost and the eligible activity. Also, costs must be reasonable and properly allocated (See 2 CFR 200, subpart E).

This year, there are limitations related to what kinds of housing counseling are reimbursable under this grant:

• Rental housing counseling (24 C.F.R. 5.100) to HUD-assisted households as defined in Appendix 1 with a focus on building financial independence and creating clear pathways toward transitioning into unassisted rental or owner-occupied housing.
• Post-purchase homeownership counseling for eligible homeowners as defined in Appendix 1 related to: (1) preventing or resolving mortgage delinquency; and (2) non-delinquency counseling (e.g., home maintenance and financial management, budgeting, refinancing, etc.).
• Home Equity Conversion Mortgage (HECM) counseling;
• Disaster preparedness and recovery counseling to HUD-assisted households and eligible homeowners to help reduce long-term recovery costs and minimize the financial impact on federal resources;
• Homeless prevention counseling services (in accordance with E.O. 14321), including information regarding treatment, recovery, and self-sufficiency.
• Other activities as outlined as a HUD priority in the Grant Agreement.

 

FAQ II(Q14): How can our agency be reimbursed for indirect costs under the FY 2025 Comprehensive Housing Counseling (CHC) Grant Program?

A: There are two methods for billing indirect costs. First, an agency may apply their approved negotiated indirect cost rate. If your agency does not have an approved indirect cost rate agreement and would like to be reimbursed for indirect costs, your agency can use the 15% de minimis rate.

For more detailed information on indirect cost rate requirements, please see 2 CFR 200.414 and Appendix IV to 2 CFR part 200.

If HUD is your agency’s federal cognizant agency and you would like to submit an indirect cost rate proposal for approval, contact your HUD Point of Contact (POC) for instructions.

FAQ II(Q15): What is the additive method for program income? 

A: The Housing Counseling Program uses the additive method for program income.  Any program income earned by a grantee may be added to their budget for the period of performance for that award.  See 24 CFR 200.307(e). 

FAQ II(Q16): My organization was recently approved by HUD to participate in the Housing Counseling Program. Are there any requirements unique to us as a first-time applicant under the FY 2025 Comprehensive Housing Counseling (CHC) Grant Program?

A: Yes, Applicants that received approval as a HUD housing counseling agency after September 30, 2024, would not have submitted a form HUD-9902 (Housing Counseling Agency Activity Report) covering the period October 1, 2023, through September 30, 2024. As such, these newly approved applicants must include a HUD-9902 for the period October 1, 2023, through September 30, 2024 with their FY 2025 application.  Failure to submit a HUD-9902 for that period will impact the Applicant's ability to reach the minimum fundable score.  Applicants that were previously required to submit a HUD-9902 will be evaluated based on the data in HUD's Housing Counseling System (HCS). 

Applicants must also be registered on the Federal government’s System for Award Management (SAM).gov site. The website can be found here. This registration must be current. The Applicant should have a registered Unique Entity Identifier (UEI). UEIs are issued by Sam.gov at no cost. 

FAQ II(Q17): Must an Intermediary or Multi-State Organization (MSO) select Subgrantees through a Request for Proposals process for the FY 2025 Comprehensive Housing Counseling (CHC) Grant Program? 

A: No. Applicants may use a method of their choosing to select members of their housing counseling subgrantee network. The Grantee must ensure that all affiliated subgrantees comply with the standards described in the NOFO and HUD Regulations (24 CFR 214) and Office of Management and Budget (OMB) regulations at 2 CFR part 200. 

Additionally, any subawards greater than $30,000 must be reported in Sam.gov. 

FAQ II(Q18): Are there reporting requirements for state or local governments that make subawards under the FY 2025 Comprehensive Housing Counseling (CHC) Grant Program? 

A: Yes. If a state or unit of general local government grantee makes assistance available on a competitive basis to affiliates or subgrantees, then they shall notify the public. The notification shall contain the elements required by 42 U.S.C. § 3545(a)(4)(C)(i).  This notification may be by any method conducive to providing information to the public.

Additionally, any subawards greater than $30,000 must be reported in Sam.gov. 

FAQ II(Q19): We experienced difficulties submitting our HUD-9902 report through our CMS. We manually reported our housing counseling activity in HCS, and the reports were late. Will our FY 2025 Comprehensive Housing Counseling (CHC) Grant Program application be penalized? 
 
A: This may affect your score related to timely HUD-9902 reporting. Office of Housing Counseling (OHC) guidance states that agencies should submit the HUD-9902 prior to the reporting deadline to account for such instances. The OHC NOFO team will evaluate timeliness across all quarters. This should ease concerns related to one-time reporting issues. Note that the Housing Counseling Online 9902 Toolkit provides a reminder that “If your agency is a HUD housing counseling grantee, failure to report will affect timely processing of grant vouchers and may negatively affect your agency’s scores in HUD housing counseling grant competitions.” 

Applicants may request a debriefing under the procedures outlined in the NOFO. During a debriefing, the applicant may present evidence if they believe that an error occurred in the scoring of the application. View the NOFO at the HUD Office of Housing Counseling HUD Exchange page. 

FAQ II(Q20): How are funds under the FY 2025 Comprehensive Housing Counseling (CHC) Grant Program allocated? 

A: The FY 2025 CHC Grant Program funding methodology awards grantees an amount based on performance within HUD’s CHC Program and other relevant criteria. See Section V.D, Selection Process, for more information. 

FAQ II(Q21): When determining subaward amounts for the FY 2025 Comprehensive Housing Counseling (CHC) Grant Program, should we place greater importance on the total number of housing counseling clients served by the agency, or on the total number of housing counseling clients served exclusively with the HUD CHC grant funds? 

A: Grantees that manage a network of subgrantees and branches should choose the allocation
method that best meets their priorities and objectives. 

FAQ II(Q22): How can applicants determine their application score under the FY 2025 Comprehensive Housing Counseling (CHC) Grant Program? 

A: After awards are made, Applicants may request a debriefing for more information about their final score 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. See Section VIII.D, Debriefing. 

FAQ II(Q23): Who is eligible to apply for the FY 2025 Comprehensive Housing Counseling (CHC) Grant Program? 

A: All housing counseling agencies (including LHCAs, Intermediaries, and MSOs) approved by HUD to participate in the Housing Counseling Program prior to the NOFO issue date, along with State Housing Finance Agencies (SHFA), who meet the eligibility requirements published in the Notice of Funding Opportunity (NOFO), are eligible to apply. Housing counseling agencies that have not received HUD approval but meet the Housing Counseling Program approval criteria at 24 CFR  214.103 are encouraged to affiliate with a HUD-approved Intermediary or SHFA. For more information, see Section II, Eligibility, of the FY 2025 NOFO. 

FAQ II(Q23): What are the recordkeeping and reporting requirements for FY 2025 Comprehensive Housing Counseling (CHC) grant recipients? 

A: FY 2025 CHC grant recipients must submit several reports to the Office of Housing Counseling over the grant period. These reports include grant activity reports and quarterly submissions of the HUD-9902 reports in the Housing Counseling System (HCS). These reports include reporting elements reflecting performance goals, objectives, and accomplishments for the award. See Section VII.D, Reporting, of the FY 2025 NOFO. Additional reporting information will be included in the Grant Agreement sent to successful applicants. 

Also, this funding is subject to all Office of Management and Budget (OMB) guidance and government-wide regulations for Federal financial assistance programs. See 2 CFR part 200, related FAQs, archived webinars on the HUD Exchange website, and the Grant Agreement for more details on Federal funding requirements. 

FAQ II(Q24): Are non-HUD approved housing counseling agencies eligible to apply for the FY 2025 Comprehensive Housing Counseling (CHC) Grant Program?

A: No. Housing counseling agencies that have not received HUD approval prior to the FY 2025 NOFO issue date but meet the Housing Counseling Program eligibility criteria set forth at 24 CFR part 214 can seek affiliation with a HUD-approved Intermediary or State Housing Finance Agency (SHFA) to access subgrant funding. Individuals, foreign entities, and sole proprietorship organizations are not eligible to directly apply for awards made under the CHC NOFO. View the NOFO at the HUD Office of Housing Counseling HUD Exchange page. 
 

FAQ II(Q25): Our State Housing Financing Agency (SHFA) is not currently participating in HUD’s housing counseling program. We would like to apply for the FY 2025 Comprehensive Housing Counseling (CHC) Grant Program as a new applicant. Is our SHFA eligible to apply? 

A: Yes. SHFAs are eligible for the FY 2025 CHC Grant Program if they have state statutory authority to provide housing counseling throughout their entire state and adhere to all Housing Counseling program requirements in 24 CFR part 214, HUD Housing Counseling Handbook 7610.1 REV-6, and other governing documents. An SHFA that is not currently participating in HUD’s housing counseling program that applies for the FY 2025 CHC Grant as a new applicant must manually submit its FY 2024 (i.e. October 1, 2023 – September 30, 2024) HUD-9902 data with its application.

FAQ II(Q26): We are a HUD-approved Intermediary that did not receive FY 2024 Comprehensive Housing Counseling (CHC) funding. We are adding a Subgrantee to our housing counseling agency network for FY 2025. As a result, our HUD-9902 data for FY 2024 does not include that Subgrantee’s housing counseling activity reporting. Can we submit this new subgrantee’s HUD-9902 data along with ours to count those clients for the FY 2025 NOFO? 

A: No. For applicants that were a HUD-approved Intermediary in FY 2024, HUD will use the applicant’s HUD-9902 information as reported in the Housing Counseling System (HCS) based on the network composition that existed in FY 2024. 

FAQ II(Q27): For the FY 2025 Comprehensive Housing Counseling (CHC) Grant Program, can LHCAs become direct grantees and be affiliated with a National or Regional Intermediary or State Housing Finance Agency? 

A: No. LHCAs that become direct grantees may not be affiliated with a National or Regional Intermediary or a State Housing Finance Agency from the time of grant execution until all funds have been expended or recaptured. This does not preclude LHCAs from joining or leaving a network between grant cycles. 

FAQ II(Q28): Is the FY 2025 NOFO Application for the Comprehensive Housing Counseling (CHC) Grant Program for Local Housing Counseling Agencies (LHCAs) the same as that for Multi-State Organizations (MSOs), Intermediaries, and State Housing Finance Agencies (SHFAs)? 

A: All CHC Grant Program applicants will complete the HUD-9906. We encourage applicants to thoroughly read all instructions as some columns apply to LCHA’s only and some columns apply to MSOs, Intermediaries, and State Housing Finance Agencies (SHFAs). MSOs, Intermediaries, and SHFAs will also submit the HUD-9906 Chart A Supplement. See Section IV, Application Contents and Format.

FAQ II(Q29): On the FY 2025 HUD-9906 Chart A Supplement (Excel), should Intermediaries, SFHAs, or MSOs include Subgrantees and/or Branches that provided housing counseling during a part of FY 2024 but will not be seeking funds under the FY 2025 Comprehensive Housing Counseling (CHC) Grant Program? 

A: The HUD-9906 Charts require information only for subgrantees and/or branches that the Applicant intends to fund under the FY 2025 CHC Grant Program.  Accordingly, information on past subgrantees and/or branches to which funds will not be suballocated under the FY 2025 NOFO should not be included. 

FAQ II(Q30): For which scored items will HUD use its own records (i.e. the applicant will not provide this information on HUD-9906 Charts)?

A: HUD will use its own data sources to score the following items:
• Average length of a Home Equity Conversion Mortgage (HECM) counseling session
• Proportion of clients from rural areas
• Total number of clients served
• Previous grant award amounts
• Services provided
• Performance Review findings
• Timely validation of agency Housing Counseling System (HCS) profile
• Timely submission of HUD-9902 reports
• Use of a client management system (CMS) to submit HUD-9902 reports
• Grant performance (timely execution, use of HUD funds, and funds recapture)
• Positive outcomes of counseling (HUD-9902 Section 10)

FAQ II(Q31): How will HUD evaluate our work with Rural and Low-Income communities for the FY 2025 Comprehensive Housing Counseling (CHC) Grant Program? 

A: HUD will use previously reported data to determine the extent that an Applicant (and, if applicable, its network) serves low-income clientele as well as clients from a “rural area” (as defined by the U.S. Department of Agriculture at 7 CFR § 3550.10). 

FAQ II(Q32): Our agency has a relatively high cost per client. Will that negatively affect our application score for the FY 2025 Comprehensive Housing Counseling (CHC) Grant Program?

A: HUD evaluates the Applicant’s Housing Counseling Program actual expenses for the period October 1, 2023, through September 30, 2024 in Chart D. Applicants must include total housing counseling program expenses from all funding sources for its housing counseling program (i.e. not just funding from HUD). MSOs, SHFAs, and Intermediaries must include total program expenses for their entire network. Agencies that became HUD-approved during the past year should ensure their expenses reflect the entire FY 2024, and not just that portion for which the agency was HUD-approved. 

Applicants may provide a narrative explanation of an inordinately high cost per client. This optional narrative provides an opportunity for an applicant to receive an adjustment point for Rating Factor 3(b) Cost Per Client.

FAQ II(Q33): Have there been any changes to the Funding Methodology for the FY 2025 Comprehensive Housing Counseling (CHC) Grant Program?

A: There are two significant changes to the FY25 CHC Grant Program’s funding methodology. First, HUD may provide incentive funding for awardees employing counselors who become HECM-certified during the period of performance. Second, HUD may adjust the base award according to previous years’ CHC grant performance, including timely use of HUD funds and funds recapture. See Section V.D., Selection Process, for more information.  

FAQ II(Q34): Will Intermediaries that are funded through the FY 2025 Comprehensive Housing Counseling (CHC) Grant Program be able to make changes to their Subgrantee list?

A: Yes, Intermediaries will be able to make changes to their Subgrantee list after awards are made. To do this, they must submit a written request and detailed justification to HUD. These requests for amendments are required and are subject to HUD approval. HUD reserves the right to adjust the award amount if the number of Subgrantees and funded Branches in a Grantee’s network changes significantly from that proposed in the grant application. For an Intermediary, State Housing Finance Agency (SHFA), or Multi-State Organization (MSO), a significant change might include, but is not limited to, a 25 percent or greater decrease in the number of their Subgrantees and funded Branches from that stated in their grant application. 

FAQ II(Q35): HUD-9906, Chart A, Fields B and C of the FY 2025 Notice of Funding Opportunity (NOFO) will not allow me to enter a percentage symbol (%).

A: In the HUD-9906, Chart A, Fields B and C, enter a whole number between 0 and 100. HUD understands that this represents a percentage. 

FAQ II(Q36): In the FY 2025 Comprehensive Housing Counseling (CHC) Grant Program, Field C of the Chart A Supplement (Excel) states “ % of Award Applicant intends to Allocate to its Branches and Subgrantees.” I can complete this section for each of my subgrantees and branches, but the main applicant box is grayed out. Please advise. 

A: Applicants only need to list the suballocation for each Subgrantee and Branch. The total of the suballocation percentages found at the bottom of Chart A Supplement (Excel) will be transferred to Chart A, Field C (% of Award Applicant intends to Allocate to its Branches and Subgrantees) of the HUD-9906 pdf file. 

FAQ II(Q37): What documentation do I need to submit with my application as proof of a partnership with an HBCU or other MSI for the FY 2025 Comprehensive Housing Counseling (CHC) Grant Program’s HBCU/MSI funding initiative?

A: Applicants must submit:
1. 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

2. Documentation of the partnering college or university's status as an HBCU or other MSI.

FAQ II(Q38): How does the FY 2025 Comprehensive Housing Counseling (CHC) Grant Program’s HBCU/MSI funding initiative affect the maximum award amount?

A: Applicants who are awarded MSI funding will receive that funding in addition to the amount they will receive for their CHC grant, if Applicants meet the minimum fundable score required by the CHC grant and provide a complete response to all questions on the HUD-9906, Chart E.

FAQ II(Q39): Our organization is an HBCU/MSI and would like to pair with more than one housing counseling agency under the FY 2025 Comprehensive Housing Counseling (CHC) Grant Program’s HBCU/MSI funding initiative. May we partner with more than one housing counseling agency Grantee?

A: Yes, an HBCU/MSI may partner with more than one grantee as long as the counseling activities are accurately accounted for and charged. The MSIs and the grantees must create a system to track the duties performed and the costs incurred for performing such duties. HUD will not reimburse the grantee for the same portion of service(s) or good(s) already covered by another funding source. Grantees must have adequate internal controls to ensure there is no double-billing.

FAQ II(Q40): Where can I find a list of HBCUs and MSIs for the FY 2025 Comprehensive Housing Counseling (CHC) Grant Program?

A: The Department of Education designates Historically Black Colleges and Universities (HBCUs) and other Minority-Serving Institutions (MSIs) and a list appears on the latest Department of Education (DOE) MSI Eligibility Matrix as found here.

FAQ II(Q41): Will prepurchase counseling be eligible for reimbursement?

A: No. Housing counseling agencies are free to use alternative funding to provide pre-purchase counseling. HUD is prioritizing private market investment and encouraging the use of diversified funding and lender funded housing counseling. However, group education workshops covering financial literacy and the homebuying process are still reimbursable.

FAQ III(Q1): Is the Housing Counseling Training (HCT) Grant Program a new grant?

A: No. Historically, the Housing Counseling Training (HCT) grant was published under a separate and self-standing Notice of Funding Opportunity (NOFO) and identified as ‘Training NOFO’ (TNOFO). This grant is now being combined with the Comprehensive Housing Counseling (CHC) and Homeownership Initiative (HI) Grant Programs under a single announcement.

FAQ III(Q2): What information does an Applicant need to provide to explain their training experience when they did not receive the Training Grant (now known as the HCT Grant Program) previously?

A: An Applicant that has not received the Training Grant in the past will be required to provide narratives in each Rating Factor, explaining how their training program meets the experience and past performance requirements of the HCT Grant Program.

FAQ III(Q3): What is the purpose of the Housing Counseling Training (HCT) Grant Program?

A: This program supports the training of housing counselors to improve and standardize the quality of housing counseling. The training is to be accessible to all counselors nationwide. This program supports both general housing counseling training and training in specialized topics.

FAQ III(Q4): Who is eligible to apply for a Housing Counseling Training (HCT) Grant Program?

A: Eligible applicants are public or private tax-exempt non-profit 501(c)(3) organizations and governmental organizations with at least two years of experience providing housing counseling training services nationwide to housing counselors employed by Participating Agencies.

FAQ III(Q5): Does the applicant need to submit a Training Work Plan with their application?

A: Yes. All applicants must submit a Training Work Plan that describes in detail their plans to develop and administer proposed training services, including administrative tasks, marketing, training courses to be offered, delivery methods, scholarships, and proposed training partners (if applicable).

FAQ III(Q6): Do I have to apply for the CHC Grant Program to receive HCT funds?

A: No. However, only eligible applicants that apply for the HCT Grant Program are also eligible to apply for an HCT-MSI award, provided they can meet all other program requirements set forth in the NOFO.

FAQ III(Q7): Are Local Housing Counseling Agencies excluded from applying for the HCT Grant Program?

A: No, a Local Housing Counseling Agency is not excluded. However, all applicants must have the necessary two years of experience providing housing counseling training services nationwide to housing counselors employed by Participating Agencies.

FAQ III(Q8): Can the nationwide training be restricted to an agency’s network members?

A: No. Neither past or proposed nationwide training nor scholarships may be restricted to Affiliates or Branches of a specific Intermediary or Participating Agency or conducted in a way that results in an advantage to Affiliates or Branches of a training Grantee.

FAQ III(Q9): Can an Applicant partner with another entity to meet the requirement for two years of experience providing nationwide training to counselors?

A: No, the Applicant itself must have the required two years of experience providing training on a nationwide basis.

FAQ III(Q10): Who can the Applicant utilize to provide the training identified in their proposed plan?

A: The Applicant may utilize in-house staff, Subgrantees, Training Partners, qualified third-party trainers, and consultants with requisite experience and capacity to provide the training.

FAQ III(Q11): What are Training Partners?

A: Training Partners are agencies and organizations that have at least two years of experience providing housing counseling training services to housing counselors employed by participating agencies. Training Partners may be state housing finance agencies; state, local, and tribal government agencies; housing counseling coalitions and networks; housing industry associations; governmental agencies; 501(c)(3) private and public organizations; or for-profit organizations. The HCT Grant Program emphasizes the use of training partnerships with local and state-wide organizations to provide additional place-based training on state and local issues.

FAQ III(Q12): What does a training scholarship cover under the HCT Grant Program?

A: A scholarship can cover the full or partial costs for the training, including assistance with travel, lodging, and tuition expenses. Scholarships are to be awarded only to housing counselors employed by a HUD Participating Agency or persons enrolled in a HUD certified housing counselor workforce development program sponsored by the HCT grantee, including military veterans and service members and/or an institution of higher education including, but not limited to, a Historically Black College or University (HBCU), Tribal College or University (TCU), or other Minority Serving Institution (MSI).

FAQ III(Q13): Can an Applicant be a recipient of both CHC MSI funds and HCT MSI funds? What is the difference between them?

A: Yes, an applicant can be a recipient of both MSI awards if they meet the requirements of both programs. The CHC MSI award is focused on the provision of housing counseling services, whereas the HCT MSI award is structured to build up the housing counseling workforce by training MSI attendees to become HUD-certified housing counselors.

FAQ III(Q14): Do applicants have to complete Chart E to apply for an MSI award under the HCT Grant Program?

A: No, as Chart E only applies to applicants applying for MSI funds under the CHC Grant Program. Applicants seeking MSI funds under the HCT Grant Program simply need to submit Chart G in full, provide a description of the Housing Counseling Workforce Development program to be administered, along with a Letter of Commitment signed by an authorizing official of the MSI certifying that a partnership is in place.

FAQ III(Q15): Are additional forms required to apply for HCT-MSI funds?

A: No, only the HUD-92910 form (Chart G) is required to apply for HCT-MSI funds.