IDA Policies and Procedures - AAA Fair Credit Foundation

Utah Individual Development Account Network
Policies and Procedures

Mission & Vision
The mission of AAA Fair Credit Foundation’s Utah Individual Development
Account (IDA) Network is to create opportunities and resources for low and
moderate income Utahns at or below 200% of the federal poverty level to
increase their personal net worth through matched savings accounts that can be
used for home-ownership, post secondary education, or vocational training, small
business start-up or expansion, and/or assistive technologies for work related
activities and develop savings habits that will maintain financial security.
The vision of the IDA is to promote economic stability in local communities and
increase economic mobility for lower income working Utahns.

Fair Credit Foundation (FCF) values justice and believes that poverty is primarily
caused by economic factors and that solutions to poverty are found by
encouraging asset building through savings, homeownership, microenterprise,
higher education/training and assistive technologies for work related activities.
FCF values the dignity and inherent worth of all individuals and believes that all
people have the right to accumulate assets.

FCF values the knowledge gained from the experience of those who live in
poverty and believes that providing financial fitness opportunities will
encourage individual fiscal responsibility and permanent habits of saving.
FCF values accountability and integrity among all parties and is committed to
treating clients and community partners with respect and fairness.
FCF values mutual/community responsibility, and believes that long-term
solutions to poverty require the collective involvement of individuals, families,
communities, economic and government systems.

Description of the Network
AAA Fair Credit Foundation provides Individual Development Accounts to low
and moderate income working Utahns. Network members include
representatives from nonprofit community based organizations such as 501(c)3s
and government entities, financial institutions, the business community,
educators, consumer credit agencies, public policy makers, low and moderate
income people and private citizens interested in long term solutions to poverty.
Fair Credit Foundation’s roles and responsibilities are clearly developed and
determined based on partner organization’s unique core competencies.

There are four key elements:
1. Community Base Organizations represent direct social service
organizations, have strong credibility and ongoing relationships with low
income people and recruit and support IDA savers;
2. Financial Partners provide financial expertise, financial literacy training,
funds for match money and house IDA accounts;
3. Network Management is provided by AAA Fair Credit Foundation, a
statewide organization with existing partnerships with Utah’s direct social
service providers.

Match Rate and Qualified Withdrawals
FCF will match participant’s savings at a rate of 3:1. IDA participants will create
a monthly savings goal and identify an asset purchase goal before they begin
saving. IDA participants will be expected to save at their goal rate each month. In
the event of an emergency, IDA participants will meet with their certified finance
counselor and follow procedures outlined in the policies and procedures manual.
Participants can save a maximum of $1,500 over a 12-36-month savings term. The
minimum monthly savings amount is $15; the maximum is $62.50. At the end of
the savings term, the money goes directly to the vendor for the asset purchase
specified in the participant’s savings plan agreement and the individual asset
plan. Form: F IDA003 Revision: 05/25/2017 3

Qualified asset purchase includes:

First time Home purchase.
Accredited post secondary education including vocational training
Small business start- up or capitalization.
Assistive Technologies for work related activities.

Account Structure
1. Participant’s accounts are joint signature accounts with AAA Fair Credit
Foundation and the participant.
2. Participants make monthly deposits at designated locations of the
participating bank.
3. The financial institution shall pay at least a market rate of interest on the
individual development accounts;
4. The financial institution shall not require an account holder to make any
purchase or enter into any commercial transaction with a specific individual,
business, financial institution or other entity.
5. Match Money accounts are held separately.

Match rate
At the completion of their savings plan, savers deposits will be matched at a rate
of 3:1

Savings Plan
Individual Savings plans will be determined in consultation with the certified
finance counselor after successful completion of the basic financial literacy
training. The certified finance counselor will assist the participant determine a
realistic monthly savings amount and a specific asset goal. Participants will be
asked to save $15 to $62.50 per month for 12 to 36 months to a maximum of
$1500.

Participant Requirements
1. Be at least 18 years old;
2. Living in Utah;
3. Earned income that does not exceed 200% of the federal poverty level
4. Net assets that do not exceed $10,000.00 excluding one car and one home.

Eligibility:
The following are minimum criteria for the IDA program:

Successful completion of financial management training is required before
applications will be accepted.
Complete asset-specific training for selected asset goal prior to asset
purchase.
Sign a saving’s agreement to save a minimum of $15 and maximum of $62.50
of earned income per month.
Allow the Fair Credit Foundation to review their credit report; and, if
necessary, address any credit issues that would inhibit the success in
purchasing the desired asset.
Agree to abide by the program’s rules and responsibilities as described by the
program staff and in the written materials received and meet income eligibility requirements by submitting proof of earned income that falls at or below 200% of the federal poverty level.

Income determination
Income determination reflects all income earned and unearned and includes the
following:

Money wages and salaries before any deductions
New receipts from non-farm or farm self-employed receipts from a person’s
own business or from an owned or rented farm after deductions for business
or farm expenses
Regular payment from Social Security Administration (gross benefits),
railroad retirement, unemployment compensation, strike benefits from union
funds, workers’ compensation, veteran’s payments, public assistance, training
stipends, alimony, child support and military family allotments
Private pensions, government employee pensions (including military
retirement pay)
Dividends, interest, net rural income, net royalties and periodic receipts from
estates or trusts Form: F IDA003 Revision: 05/25/2017 5
A household must meet the income requirement for three months before they are
accepted into Fair Credit Foundation savings program. If during the time of
saving the family’s income increases that increase will not effect their
participation in the IDA Program. The following documents are acceptable for
income verification:
Copies of paychecks or pay stubs.
Written statements from employers.
Letters or other documents from income sources, if dated within the last 30
days.
If self-employed, accounting and other business records showing net income
Most recent tax return.
Other documents the program site has reason to believe will verify the
income of the household member.

Income Exclusions

Capital gains.
Any assets drawn as withdrawals from a bank, the sale of property, a house
or a car.
Tax refunds, gifts, loans, lump sum inheritances, one-time insurance
payments, or compensation for injury.
Non-cash benefits such as employer paid or union paid portion of health
insurance or other employee fringe benefits, food or housing received in lieu
of wages, the value of food and fuel produced and consumed on farms, the
imputed value of rent from owner-occupied non-farm or farm housing, and
federal non-cash benefit programs such as Medicare, Medicaid, food stamps,
school lunches, housing and other emergency assistance.
Any portion of Social Security benefits deducted to pay Medicare premiums
that will not be reimbursed.

Application Review
Prospective applicants have one year after completion of personal financial
management classes to complete the application. Applications are in electronic
format. FCF will distribute paper applications, upon request. Form: F IDA003 Revision: 05/25/2017 6
Once the application has been submitted, the applicant has one month to submit
all supporting documents.

The purpose of the application review is to:

Determine eligibility to participate in the program.
Identify any potential barriers to successfully completing the program and
make appropriate referrals for assistance.

Application supporting documents include

Documentation of income at or below 200% of the federal poverty level.
Proof of household income (outlined on page 4)
Three months of checking and savings banks statements, retirement,
stocks, bonds and other investment statements.
Most recent tax return.
Completed household budget including proposed monthly IDA savings.
Credit report dated within the last quarter.

Application Approval
A final decision based on the following will be made within 2 weeks of receipt of
complete application based on the following:

All eligibility requirements met.
Applicant’s current financial situation indicates their ability and capacity to
achieve the identified savings goal.

Saver documents
Upon approval applicants, must submit the following documents within 2
weeks. These include the following:

Savings plan agreement.
Beneficiary designation form.
Program Evaluation release form.

Account opening
Saver must open the account within two weeks of approval at an authorized
financial institution. Form: F IDA003 Revision: 05/25/2017 7

Emergency Withdrawal Policy
Participants may make emergency withdrawals after 6 months of participation
and remain in good standing under the following conditions.
After 6 months of IDA savings, participants are allowed one opportunity within
a 12-month period to withdraw all or some of their savings from their IDA
account. While they are strongly discouraged from doing so, emergencies can
arise which necessitate a withdrawal.
Participants are required to discuss their situation with the program staff and
assess options. The following procedures are followed in cases where an
emergency withdrawal is approved.
To be eligible for an emergency withdrawal, participants must have been
enrolled in the program for at least six months and shown good progress in
meeting their savings commitment. If they have not met these criteria they can be
removed from the program.
Emergency withdrawal uses: Emergency withdrawals will only be approved
when, in the judgment of the program staff, the IDA funds are necessary to:

Prevent eviction of a participant or participant’s family from their residence;
Prevent foreclosure on a participant’s primary residence;
Pay for critical health care services for a participant or a participant’s family
member; pay for critical living expenses, such as food supplies or utility
expenses, following a participant’s loss of employment.
Amount of withdrawals: Approved emergency withdrawals may be made in
any amount up to a participant’s entire account balance. Withdrawals will not
include matched funds.
Forfeiture of match: Participants who make emergency withdrawals will have
up to 12 months to reimburse their account or the account will be closed and all
matching contributions forfeited. Form: F IDA003 Revision: 05/25/2017 8
Alternatives to emergency withdrawals: In the event the participant’s request to
make an emergency withdrawal is not approved, the participant may choose to:
Make do without the emergency withdrawal and continue participation in
the program;
Withdraw from the program and receive a full refund of all IDA deposits and
interest, but forfeit all matching money and jeopardize any possibility of
future program participation.
Request Procedure: IDA participants who need an emergency withdrawal
should follow the following procedure:
Complete and submit an Emergency Withdrawal Request Form to program
staff;
Schedule a meeting with a program staff to discuss the situation and to
review alternative strategies to resolve the problem;
If the request is approved, develop a revised savings plan that will allow
withdrawn amounts to be re-deposited in 12 months;
Make arrangements with program staff to authorize withdrawal of funds
from the participating financial institution.

Missed Deposit Policy:
Participants are expected to deposit as agreed in their savings plan agreement.
The following procedures will be used for missed deposits:

First missed deposit: a friendly contact will be made and documented with
the saver to see why the deposit was missed.
Second missed deposit: the certified finance counselor will contact saver and
remind him/her to deposit monthly and schedule a meeting with the financial
counselor.
Third missed deposit: If no contact with saver has been made, the saver will
be considered for termination from the program. If contact has been made
the Programs Director and Executive Director need to be involved to
determine the next step.
Final decision for termination from the program will be made by the
Programs Director in consultation with the Executive Director.
All communications with the participant will be saved in the participants file. Form: F IDA003 Revision: 05/25/2017 9

Termination:

Fraud or intentionally reporting inaccurate or misleading information.
Three missed deposits and refusing to meet with the financial counselor.
Relocation outside of Utah.
Once terminated, a participant will not be allowed back in the program for 12
months and only if they can demonstrate that circumstances have changed to
allow them to succeed in the program.

Steps for Completing Termination:

A letter is sent to the participant announcing his/her termination from the
program with specific reasons. Letter informs the participant that they have
forfeited any rights to the matching money because of termination.
Fair Credit Foundation’s Programs Director or Executive Director will contact
the financial institution holding the IDA account and transmit termination
notice requesting that the account be changed from an IDA account to an
alternative, if money remains in the account.

Successful Completion of the IDA Savings term:
Request for match money: Withdrawals require at least two weeks and must
show proof of the following:
1. Sufficient funds in the account.
2. At least 12 months of savings.
3. Completion of asset specific training.
4. Qualify for financing, if applicable.

Qualified withdrawal request must be accompanied by detailed documentation
of the planned purchase or expenditure
1. Home purchase: a copy of a purchase and sales agreement,
settlement statement, mortgage approval letter and relevant
bills such as attorney and/or home inspector.
2. Business start-up: copy of the participant’s business plan has
been approved by a small business lender, an SBA group or
submitted to the Network for approval by the Utah
Microenterprise Loan Fund. Business plans must include Form: F IDA003 Revision: 05/25/2017 10
written estimates for the cost of services or products to be
purchased for the business.
3. Education: Tuition bill from the school or training program as
well as a description of the degree program or course of study

Processing of Request for Matched Funds:

Participant will submit a copy of the qualified withdrawal request form to
IDA Program Staff.
A second IDA Staff person will verify that all signatures are in place and
confirm that program requirements have been met.
The Programs Director or Executive Director contacts the appropriate
financial institution and authorizes the institution to write a check to the
vendor.
Withdrawals must be completed within 3 months of the end of the savings
term.