ADDRESSING CLIENTS’ NEEDS DURING THE COVID-19 PANDEMIC

July 2, 2021

On June 30, 2021, the Connecticut eviction moratorium expired. However, Governor Lamont has issued Executive Order 12D which took effect on July 1. The order has the following provisions:

• UniteCT rental assistance program prior to delivering a notice to quit for nonpayment of rent. The UniteCT case number must be included on the Notice to Quit;

• if you have applied for UniteCT and you have a case in court, then you should tell the Judge about your UniteCT application. If you have not yet applied for UniteCT you must do so to be covered by this part of these protections provided by the Governor’s recent executive order.

On June 24, 2021, the Centers for Disease Control extended its eviction moratorium until July 31, 2021.

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Since March 15, 2021, when UniteCT began accepting applications:

• applications or 28.6% of the total fully submitted applications have been approved for payment of a rental and/or utility arrears. This represents $23 million in expenditures or about 6% of the total funding allocated to Connecticut;

• people have entered homeless shelters. Only 25.3% of those exiting shelter went into permanent homes;

Racial and ethnic disparities continue in recovery from pandemic-related economic hardship: According to the latest data from the Household Pulse Survey, 36% of Latinx renters, 41% of Black renters, and 16% of people of two or more races are not caught up on their rent compared to 8% of white renters.

In addition, 23% of Black homeowners and 27% of people of two or more races are not caught up on their mortgage payments compared to 3% of white homeowners.

Consequences of Eviction

The more than  130,000 tenants who currently owe rent as the result of the COVID-19 crisis are likely to suffer the following consequences when evicted:

• With 2,560 people already living in shelters, many tenants who are evicted will double up with friends or family, or sleep in cars, parks, or other outdoor settings.
• Recent studies have shown that neighborhoods with the highest eviction rates have the lowest levels of COVID-19 vaccinations. Evictions will result in spreading the virus and its newest variants throughout the State.
• Since 2017, the Center has been evaluating the effect of eviction when people search for new housing. The testing reveals that an eviction is almost certain to lead to the denial of a new unit. More than 39% of landlords indicated they would not rent to someone with an eviction record while 61% said that if the tenant could prove the eviction was withdrawn or that the tenant was permitted to stay in the unit, they would overlook the eviction record.
• . A study of mothers evicted during their pregnancies revealed that eviction harms infant health and development.

President Biden announces initiatives to support vulnerable tenants and homeowners:      

The Biden-Harris Administration announced a series of actions to help state and local governments prevent evictions and foreclosures and promote housing stability. The Administration is calling for an acceleration of the distribution of ERA funds to renters and landlords in addition to an all hands-on-deck effort by local governments, courts, community organizations, and the legal community to create alternatives to evictions. The strategies deployed include asking state and local courts to participate in eviction diversion efforts; using ARP money to prevent unnecessary evictions; accelerating and broadening state and local delivery of emergency rental assistance; ensure the 30-day eviction notice requirement for Federally-backed properties is enforced; make clear the Fair Housing Act must be followed; and leverage government channels to reach vulnerable tenants and landlords.

To prevent foreclosures, the Biden administration is extending the foreclosure moratorium for mortgages backed by HUD, the VA, USDA, and the FHFA until July 31, 2021. Once the moratoria end, HUD, VA, and USDA will take additional steps to prevent foreclosures on mortgages backed by those agencies until borrowers are reviewed for COVID-19 streamlined loss mitigation options that are affordable. The FHFA will continue to work with Fannie Mae and Freddie Mac to ensure that borrowers are evaluated for home retention solutions prior to any referral to foreclosure. 

Eviction and foreclosure moratorium status:

Connecticut Eviction Moratorium expired June 30, 2021. However, Governor Lamont has issued Executive Order 12D which took effect on July 1. Tenants: if you have applied for UniteCT and you have a case in court, then you should tell the Judge about your UniteCT application.

The national Centers for Disease Control and Prevention’s eviction moratorium has been extended to July 31, 2021. This protection is NOT automatic. It only applies to tenants who cannot pay full rent or other housing payments because they have lost income or have very expensive medical bills. To receive this protection, you must provide your landlord with a signed copy of the CDC declaration form. More information about eligibility requirements and how to complete the CDC declaration is available here.

Current foreclosure moratoriums:

• until August 31, 2021
• until July 31, 2021
• The CFPB final servicing rule will implement a foreclosure moratorium from August 31, 2021 until December 2021 that applies to most mortgages, not just federally-backed mortgages. Under the rules, servicers can only start a foreclosure if the borrower:

Tenants living in multifamily properties with a Fannie Mae or Freddie Mac backed mortgage cannot be evicted for nonpayment of rent through September 30, 2021. Additional tenant protections include not charging tenants late fees or penalties for nonpayment of rent and allowing tenants flexibility in repayment of back rent over time and not demanding a lump sum payment. Finally, landlords evicting for reasons other than nonpayment of rent must give a 30-day notice.

No foreclosure moratorium on mortgages that are not “federally-backed” or non-mortgage foreclosures: Homeowners whose mortgages are not “federally-backed” or who owe condominium fees, real estate taxes, or other real estate related taxes are not protected from foreclosure.

UniteCT Updates

On May 7, 2021, the U.S. Treasury sent out new guidance on nine enhanced policies to directly aid renters, prevent evictions, and help tenants transition to secure housing. In response to the new guidance, DOH has announced that it will make the following changes to the UniteCT program:

• Tenants will now be eligible to receive up to $15,000 in rental arrearage payments for any rent owed after March 13, 2020 regardless of the number of months owed;
•   Landlords will not be required to write-off 15% of the rental arrearage;
• If tenants are eligible for prospective rental payments through UniteCT, the tenant will not be required to contribute any rent for the first three months of prospective payments;
•   UniteCT will use income proxies to determine eligibility. If an applicant lives in a low-income census block, the applicant will not be required to submit income verification. Instead, the applicant can sign a self-attestation that they have income at or below 80% of AMI and will not have to submit paystubs or tax returns;
•   Applicants who receive benefits from Medicaid, SNAP, TANF, State Administered General Assistance (SAGA), and the state supplement will be eligible for UniteCT without additional income verification;
•   UniteCT will provide benefits to tenants who live in public or subsidized housing. Anyone who has been denied benefits because they live in public or subsidized housing should contact doh-unitect@ct.gov immediately;
• : DOH is holding meetings with landlords to inform them of the changes in the program and to encourage them to participate. Go to www.unitct@ct.gov to see the latest training or to sign up for the next available training.

Applying for UniteCT/advice for completing an application:

• UniteCT’s emergency rental and utilities assistance is available for individuals with a household income at or below 80% of AMI who have experienced a financial hardship due to the COVID-19 pandemic. Applications must be made on-line. A list of the documents which must be included with an application can be found here.  Visit https://portal.ct.gov/DOH/DOH/Programs/UniteCT to apply or call 1-844-864-8328 to get a referral to a community agency who may be able to assist tenants and landlords in applying.
• Tenants denied assistance from UniteCT will receive notice with instructions on how to appeal the denial. A tenant has 14 days from the date of denial to appeal by sending an email to unitectappeal@ct.gov stating the reason for the appeal.
•   Tenants who have not received a confirmation email once their application is submitted should email: doh-unitect@ct.gov or call 1-844-864-8328.

The UniteCT mobile tech bus will be at the following locations for the week starting
July 6, 2021:

UniteCT’s tech bus provides the necessary technology to apply for rental assistance. Tenants and housing providers who may not have access to the technology required to complete an application for rental assistance are encouraged to visit the bus. To learn more about the bus please contact the host agencies.

Bridgeport, CT

When:        Tuesday, July 6, 10am – 3 pm

Location:   Park City Communities, P.T. Barnum Apartments, 96 Bird St. Bridgeport

Contact:    Mayra Ramirez, mramirez@bridgeporthousing.org, 203-337-8870

New Haven, CT

When:        Wednesday, July 7, 10 am – 3 pm

Location:   NeighborWorks New Horizons, 730 George Street, New Haven

Contact:    Zabrina Roman, Zabrina@nwnh.net, 203-676-5915

Bridgeport, CT

When:        Thursday, July 8, 10am – 3pm

Location:   Park City Communities, Green Homes, 629 Washington Ave. Bridgeport

Contact:    Greg Johnson, gjohnson@parkcitycommunities.org, 203-337-8886

Waterbury, CT

When:       Friday, July 9, 10 am – 3 pm

Location:  Martin Luther King Jr Park, 449 North Main St, Waterbury

Contact:    Emmanuel Cruz, ecruz@nhswaterbury.org, 203-558-4547

Addressing UniteCT Issues

Complex program eligibility requirements, the voluminous required documentation, and technical challenges make it unlikely that UniteCT will successfully distribute its more than $400 million in federal rental assistance. The Center recommends the following changes to UniteCT to ensure stability and safety for Connecticut’s families: 

• Treasury guidance states that tenants who do not have adequate documentation of the amount of the rental obligation or the terms of their rental agreement may submit a written attestation. 

• Treasury guidance states that if an applicant cannot provide written documentation of income, an attestation form can be used.

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•  The landlord and tenant FAQs on the UniteCT website cannot be translated into Spanish.

•  In addition, the UniteCT website does not provide reasonable accommodations for tenants with disabilities who cannot access the UniteCT website or application.

• providing reasonable accommodations for tenants with disabilities who cannot access the UniteCT website or application;

Help for tenants

Visit the Center’s website for fact sheets on the CDC eviction bans and available rental assistance programs. FAQs about evictions, rental assistance, and housing discrimination during the Covid-19 pandemic are also available.

Help for homeowners

Fannie and Freddie expand use of interest rate reductions:  On June 30, 2021, Fannie Mae and Freddie Mac announced that they would expand their interest rate reduction programs. Flex Modification terms will be adjusted for COVID-19 hardships making interest rate reduction possible for eligible borrowers, regardless of the borrower’s loan-to-value ratio.

FHFA closes gap between Fannie and Freddie moratorium and CFPB servicing moratorium: On June 29, 2021, FHFA announced it would extend its moratorium to protect borrowers until CFPB moratorium starts. The CFPB final rule prohibits servicers from making a first notice or filing for foreclosure in most cases covered by the rule before December 31, 2021. Servicers will still be able to make a notice or filing for foreclosure on abandoned properties and those that had a foreclosure referral prior to March 2020, along with certain other exceptions. CFPB’s final rule will take effect August 31, 2021.

CFPB issues rules to facilitate transition as federal protections expire: On June 28, 2021, the CFPB issued rules to transition as federal foreclosure protections expire. The rules take effect on August 31, 2021 and ends on December 31, 2021. Under the rules, servicers can only start a foreclosure if the borrower:

This protection applies to many, but not all, mortgages.

Connecticut is using federal Homeownership Assistance Funds to assist homeowners delinquent on payments: The American Recovery Plan included funding for homeowners in danger of losing their homes to foreclosure. Connecticut will receive approximately $123 million. DOH is working with CHFA to pilot a program that will provide up to $20,000 in grants to homeowners whose income is at or below 80% of AMI and who are socially or economically disadvantaged. A pilot program is expected to begin in July 2021. Details will be posted on the DOH and CHFA websites.

Foreclosure advice: The Center is holding Foreclosure Advice Virtual Sessions. Homeowners facing foreclosure can sign up for advice sessions over video or phone. These Sessions are in addition to the considerable number of videos and materials available at www.ctfairhousing.org.

Additional resources

Payments to help with internet access:  The Federal Communications Commission has launched a temporary program to help families and households struggling to afford Internet service during the COVID-19 pandemic.  The Emergency Broadband Benefit provides a discount of up to $50 per month toward broadband service for eligible households and up to $75 per month for households on qualifying Tribal lands. Eligible households can also receive a one-time discount of up to $100 to purchase a laptop, desktop computer, or tablet from participating providers. Eligible households can enroll through a participating broadband provider or directly with the Universal Service Administrative Company (USAC) using an online or mail in application.

VISIT OUR WEBSITE FOR MORE INFORMATION ABOUT YOUR FAIR HOUSING RIGHTS IN ENGLISH, SPANISH, MANDARIN, VIETNAMESE, FARSI, RUSSIAN, ITALIAN, KREYOL, ARABIC, KHMER, AND TAGALOG.

Outreach:  To schedule trainings on COVID-19 protections for tenants, foreclosure prevention, fair housing or constituent outreach please contact Rashida Rattray, at rrattray@ctfairhousing.org