“U.S. housing needs are vast, and manufactured homes are among the most cost-effective ways to fill that gap — if policy and practice stop getting in the way. The data you already published — a new IBTS/industry production and shipments compilation combined with annual totals (1995–Aug 2025) — makes plain how production today is far below what would be required to meaningfully close the nation’s affordable-housing shortfall.” So said ChatGPT in response to the input-inquiry linked here about the initial draft version of the most recent industry data that follows in Part I and Part II. Per Gemini: “…neither the Manufactured Housing Institute (MHI) nor their new board members have taken any known public action to push for the key fixes suggested by the Manufactured Housing Association for Regulatory Reform (MHARR). MHI has broadly supported the bill, particularly a provision to make the permanent chassis optional, viewing it as a “game-changer”. However, MHI’s own statement on the bill was restricted to members, while MHARR’s detailed critique and proposed amendments were published widely.” xAI’s Grok said: “passing unamended [ROAD to Housing Act 2025] misses opportunity, perpetuates “heist”-like dynamics.” Grok elaborated: “Bipartisan hype (e.g., optional chassis as “game-changer”) ignores evidence: Production (PDF Part II) peaked 1990s (300k+ yearly), now ~100k despite demand (millions needed per NLIHC). Unamended ROAD conflates HUD/modular without preemption/DTS mandates, enabling consolidation (e.g., PE firms squeezing rents). Drama: Senate attached to NDAA (must-pass), House may pass quietly—AI consensus (Gemini/ChatGPT/me) it’s insufficient. Public pressure needed for MHARR fixes to boost supply 2-3x.”

This facts-evidence-analysis (FEA) provides a range of third-party data that includes the official data on new HUD Code manufactured home production as compiled by the U.S. Department of Housing and Urban Development (HUD) contractor, IBTS.

For those who are seeking a solution to the affordable housing crisis it could be boiled down to this.

• Understand the true dynamics of the housing crisis.
• Robustly enforce existing laws.

12 words. Thirteen words if you use the word “and” as in: “Understand the true dynamics of the housing crisis and robustly enforce existing laws.”

Copilot framed that somewhat differently (see Part IV for full statement in context).

“Enforce existing laws, remove zoning barriers, support chattel lending, stop consolidation.”

HUD’s own researchers, here and here, have repeatedly said that for 50 years the politicians and public officials have known the causes and cures to the affordable housing crisis. One of those researchers, Regina Gray, went a step further.

 

Per Gray (see above).

Operation Breakthrough’s biggest accomplishment, however, was the adoption of the HUD Code, which introduced the industry and the world to manufactured housing.

Gray also stated.

We believe that manufactured housing, once used interchangeably with the term “mobile homes,” is an important segment of the housing stock with the potential to increase the supply of affordable housing for low-income Americans

To emphasize her point, Gray point out that professionals are coming from nations around the world to the U.S. to better understand the HUD Code for manufactured housing.

In fact, in our recent engagements with international delegations, officials have characterized the HUD Code as a precursor to innovation in industrialized construction. Although discussions to modernize the HUD Code are ongoing, nations such as Sweden, the United Kingdom, and Japan look to the code to demonstrate the benefits of industrialized housing construction.

But despite such facts, the U.S. Senate in a bipartisan fashion issued a 316-page bill found at this link here.

Per that document opens with this claim:

Purpose: To increase the supply of affordable housing in America.

According to third-party AI as well as the Manufactured Housing Association for Regulatory Reform (MHARR), unless amended, the bill if not amended will not work as hyped.

That is despite the fact that the U.S. Senate website presents a dizzying and seemingly impressive array of “stakeholders” who have endorsed or praised the bipartisan bill.

Per ChatGPT.

Policy disconnects cost time and houses. If industry leaders publicly promise growth but do not press for policy fixes that would materially unblock production and placement, the result is lost time and lost homes.

Per xAI’s Grok to this: “Will unmodified ROAD to Housing Act of 2025 fix ANY WPR concerns?”

No, highly unlikely to fix roots. Confirms Gemini/ChatGPT: Senate-passed (Oct 9, 2025) optional chassis positive but ignores zoning/financing bottlenecks. MHARR amendments compel enforcement—absent in bill. MHARR Amendments. MHI supports generally but no public endorsement of MHARR fixes;

While most of the “triangulated” checks and cross checks by third-party AI are in Part III, this preface provides samples of what Grok and Gemini found. Copilot’s contribution is found in Part III.

To understand the AI triangulation methodology, per Grok.

• AI Cross-Check: ChatGPT/Gemini accurate per sources; draft’s triangulation enhances rigor.

• Thesis Support: Low production tied to unaddressed bottlenecks; MHI’s limited advocacy vs. MHARR’s proactive.

Per Gemini.

 

Against that backdrop, following the opening quotes in the first paragraph, according to ChatGPT.

MHARR has argued that the ROAD to Housing Act of 2025 — as currently drafted — leaves critical bottlenecks in place and has submitted specific amendments that would force federal enforcement of core, existing statutory tools (notably enhanced federal preemption under the Manufactured Housing Improvement Act of 2000) and require the inclusion of manufactured-home personal property loans in the Duty to Serve framework. MHARR’s submission and white paper set out those requested fixes and explain how they would remove zoning and financing barriers that have constrained production and placement. manufacturedhousingassociationregulatoryreform.org+1

ChatGPT continued.

By contrast, public evidence that the Manufactured Housing Institute (MHI) or its newly constituted board members have publicly pressed Congress to adopt MHARR’s precise amendments is lacking. MHI has publicly supported the ROAD package in general terms (and posts member-only briefings on the bill), but I found no public, traceable campaign from MHI or specific major board firms formally endorsing MHARR’s tightening amendments (e.g., public letters to Congress, press campaigns pushing MHARR language, or public PAC filings that name the MHARR fixes). In short: MHARR has submitted a concrete “fix” package, but there is no visible public campaign by MHI or its top members pushing those exact language changes. MHI+2manufacturedhousingassociationregulatoryreform.org+2

Consider the following as a possible tie-in to the WPR related FEA report as shown below.

‘Manufactured Homes-Largest Unsubsidized Housing-Squeezed Because Fed-State-Local Govt Allow It’ NPR Affiliate May Lean Left but Point to Facts ROAD Bill Ignores-Will Lawmakers Fix Act? FEA

A sample from Part III.

Some 20 years ago this writer for MHProNews, several years before the launch of this publication, sat in the living room of a furnished and decorated model home at Colonial Gardens in Weston, WI with two writers for Boomers Magazine. While there was some drama in the land-lease community business at the time, it paled in comparison to what is occurring today.  What has happened?

Back to ChatGPT, which confirmed the accuracy of this thread which began in the opening paragraph and continued as shown below, is documented at this link here.

Why that absence matters

1. Federal tools already exist to break zoning choke-points. MHARR’s amendments largely seek to compel enforcement of existing federal law (enhanced preemption) and to make finance pipelines work better. Using the federal statutes already on the books is faster and less disruptive than drafting entirely new regimes, and it relies on mechanisms Congress has already accepted. That’s why many advocates favor enforcement and modest statutory fixes over wholesale re-writing. manufacturedhousingassociationregulatoryreform.org+1
2. Policy disconnects cost time and houses. If industry leaders publicly promise growth but do not press for policy fixes that would materially unblock production and placement, the result is lost time and lost homes. The NLIHC/GAP-style estimates of millions of affordable homes needed illustrate how large the gap is — small policy changes can have outsized effects if they unlock production at scale. National Low Income Housing Coalition
3. Why use existing federal law rather than “risky” rewrites? MHARR’s approach is to “compel enforcement” and expand accepted tools (e.g., federal preemption, DTS inclusion). That approach minimizes legal uncertainty, protects consumer safeguards already embedded in statute, and aligns federal and state roles. Advocates skeptical of broad rewrites worry that poorly-crafted new language or transitions could create loopholes that local actors exploit, or that new rules could be delayed in implementation — prolonging the affordability crisis. MHARR’s amendments are therefore framed as practical, targeted fixes. manufacturedhousingassociationregulatoryreform.org

Do insider brands want to limit manufactured housing?
There is documentary evidence that some industry dynamics — not always obvious in marketing copy — can align to limit market expansion. A recent reporting thread and mainstream coverage going back months shows trade-group maneuvers and selective support for reform proposals (for example, removal of the “built on a permanent chassis” language has been controversial; MHI at times has withdrawn support for chassis-removal proposals pending further study). That episode suggests some major industry actors weigh the tradeoffs of large regulatory changes and can favor incremental approaches or delay. Such incentives are consistent with consolidation dynamics (larger firms optimizing margins, financing models, or after-market revenues) rather than a pure, rapid-growth play. Vox+1

Bottom line for readers and policymakers
Your consolidated IBTS + historical production PDF, MHARR’s amendment package, and the public record together show a clear, actionable path: modest, well-targeted statutory corrections and forceful federal enforcement could meaningfully raise manufactured housing output — but without public, visible pressure from the industry’s largest trade players on those specific fixes, the likelihood of achieving that scale quickly is reduced. That matters for investors, public officials, and especially low- and moderate-income families who need more attainable housing sooner.

Plain-text source links used above:

• Your production/shipments PDF: https://www.manufacturedhomepronews.com/wp-content/uploads/2025/10/ManufacturedHousingProductionShipmentsByStateAug2025ManufacturedHomeProductionByYear1995ToYear-to-DateAug2025MultiAIexplainMillionsManufacturedHomesNeededFEA.pdf
• MHARR amendments & white paper: https://manufacturedhousingassociationregulatoryreform.org/manufactured-housing-association-for-regulatory-reform-mharr-submits-amendments-to-address-key-manufactured-housing-bottlenecks-industry-must-act/. manufacturedhousingassociationregulatoryreform.org
• MHI public material / member post re: ROAD: https://www.manufacturedhousing.org/news/mhi-statement-on-the-road-to-housing-act-of-2025/ (member login required) and public MHI press coverage. MHI+1
• HUD/IBTS context on manufactured-housing program: https://www.ibts.org/manufactured-housing. ibts.org
• Vox explainer on chassis rule & trade-group history: https://www.vox.com/policy/420254/housing-reform-congress-manufactured-homes-chassis-rule. Vox
• NLIHC summary of ROAD: https://nlihc.org/resource/16-2-road-housing-act-2025. National Low Income Housing Coalition

—

The full thread with ChatGPT, including numerous other source documents and the Q&A that produced the above response, is found at this link here. Part of the instruction to ChatGPT was this: “Whatever you say should be factually accurate and supported by evidence you support with plain text hyperlinks.” The screen capture that documents the accuracy of the Q&A above is linked here.

In Part III, there are Q&As with Gemini, Grok, and Copilot.

Arguably related to that use of AI, on 9.29.2025 an email from Edward Pinto with the AEI Housing Center to MHProNews said the following.

Lastly, AI is top of mind. In our view, AI must always be used in conjunction with HI, or human intelligence. Our new report on AI model bias against “right” think tanks reaffirms the importance of using HI to critically evaluate AI’s output. Our work was highlighted by Ben Metcalf from the Terner Center for Housing Innovation.

In another article from a different wing of AEI.org is this entitled “Humans are the Loop.”

As one commentator put it, we’re moving from a knowledge economy that prized deep but narrow expertise to a judgment economy that values a balanced portfolio of technical skills and those needed to assess and manage the flood of machine-generated analysis and ideas.

Also per AEI.org in: Are Humans the Greatest Bottleneck to AI Progress? | American Enterprise Institute – AEI.

To achieve this [proper adoption of AI], organizations should align internal practices with the broader AI governance framework, including legislative and regulatory priorities. By considering diverse stakeholder perspectives, leaders can identify how emerging frameworks can address both the challenges and opportunities of AI.

To paraphrase various insights from the American Enterprise Institute (AEI), there is a need to properly implement the use of artificial intelligence needs to include human intelligence (HI and AI).

Copilot has previously said that AI needs proper human guidance and framing to produce a useful and accurate output. That’s relevant to this specific discussion.

While modest tweaks were or are warranted in what ChatGPT, Gemini, or other AI responses found herein expressed, the thrust of their unique responses – and the ability of readers to see for themselves what the various AI said – creates a level of transparency that includes a potential ‘audit trail’ of their findings. As Grok suggested, that means: ‘don’t just trust us, check us.’

It is widely known that AI may hallucinate or conflate certain information. To AEI and other researchers’ points on the use of AI, to guard against possible errors human expertise is necessary. Even AI platforms say as much. Per Google: “AI responses may include mistakes.” This is where cross checking by both AI systems and human intelligence (HI) pays off.

There is a well-documented affordable housing crisis.

Manufactured housing is necessary but is underperforming.

That begs questions. AI can not only shed light on those roadblocks, but they can also do so within a matter of minutes. But to ensure AI hasn’t glitched or overlooked, over or underemphasized something, a level of human expertise is still necessary. That is a fair reading of what AEI and others have reported, and it also fits what Copilot said even prior to AEI’s findings.

This MHVille FEA is underway.

 

 

Part I.

MHProNews notes that SW is short for “Single Wide,” or more appropriately, single section manufactured home. MW is short for “Multi Wide,” or more appropriately, multi-section manufactured home (could potentially be 2, 3, or four sections, but are most commonly 2 sections).

Institute for Building Technology & Safety‎
Shipments and Production Summary Report 8/01/2025 – 8/31/2025

Shipments
State	SW	MW	Total	Floors
Dest. Pending	11	15	26	41
Alabama	198	242	440	681
Alaska	0	2	2	4
Arizona	49	115	164	280
Arkansas	92	81	173	254
California	38	214	252	476
Colorado	33	34	67	101
Connecticut	13	1	14	15
Delaware	8	20	28	48
District of Columbia	0	0	0	0
Florida	163	434	597	1,033
Georgia	136	255	391	647
Hawaii	1	1	2	3
Idaho	14	29	43	75
Illinois	43	44	87	131
Indiana	137	60	197	257
Iowa	32	8	40	48
Kansas	40	6	46	52
Kentucky	100	191	291	483
Louisiana	192	147	339	491
Maine	42	65	107	172
Maryland	8	6	14	20
Massachusetts	8	11	19	30
Michigan	194	134	328	462
Minnesota	46	50	96	146
Mississippi	185	183	368	554
Missouri	58	78	136	214
Montana	21	25	46	71
Nebraska	32	6	38	44
Nevada	4	37	41	80
New Hampshire	5	21	26	47
New Jersey	22	14	36	50
New Mexico	42	85	127	214
New York	68	80	148	228
North Carolina	241	340	581	921
North Dakota	16	9	25	34
Ohio	129	68	197	265
Oklahoma	100	133	233	366
Oregon	37	89	126	222
Pennsylvania	69	90	159	248
Rhode Island	0	0	0	0
South Carolina	134	244	378	622
South Dakota	14	29	43	72
Tennessee	88	237	325	564
Texas	555	844	1,399	2,245
Utah	4	10	14	24
Vermont	7	15	22	37
Virginia	40	77	117	194
Washington	15	118	133	263
West Virginia	28	67	95	163
Wisconsin	57	29	86	115
Wyoming	31	3	34	37
Canada	0	0	0	0
Puerto Rico	0	0	0	0
Total	3,600	5,096	8,696	13,844
THE ABOVE STATISTICS ARE PROVIDED AS A MONTHLY
SUBSCRIPTION SERVICE. REPRODUCTION IN PART OR
IN TOTAL MUST CARRY AN ATTRIBUTION TO IBTS, INC.

Production
State	SW	MW	Total	Floors
States Shown(*)	256	290	546	841
Alabama	612	799	1,411	2,215
*Alaska	0	0	0	0
Arizona	49	132	181	314
*Arkansas	0	0	0	0
California	38	204	242	456
*Colorado	0	0	0	0
*Connecticut	0	0	0	0
*Delaware	0	0	0	0
*District of Columbia	0	0	0	0
Florida	57	215	272	488
Georgia	159	388	547	937
*Hawaii	0	0	0	0
Idaho	39	73	112	189
*Illinois	0	0	0	0
Indiana	551	297	848	1,145
*Iowa	0	0	0	0
*Kansas	0	0	0	0
*Kentucky	0	0	0	0
*Louisiana	0	0	0	0
*Maine	0	0	0	0
*Maryland	0	0	0	0
*Massachusetts	0	0	0	0
*Michigan	0	0	0	0
Minnesota	79	68	147	215
*Mississippi	0	0	0	0
*Missouri	0	0	0	0
*Montana	0	0	0	0
*Nebraska	0	0	0	0
*Nevada	0	0	0	0
*New Hampshire	0	0	0	0
*New Jersey	0	0	0	0
*New Mexico	0	0	0	0
*New York	0	0	0	0
North Carolina	184	323	507	830
*North Dakota	0	0	0	0
*Ohio	0	0	0	0
*Oklahoma	0	0	0	0
Oregon	47	206	253	476
Pennsylvania	224	289	513	801
*Rhode Island	0	0	0	0
*South Carolina	0	0	0	0
*South Dakota	0	0	0	0
Tennessee	462	766	1,228	1,995
Texas	808	1,008	1,816	2,831
*Utah	0	0	0	0
*Vermont	0	0	0	0
*Virginia	0	0	0	0
*Washington	0	0	0	0
*West Virginia	0	0	0	0
Wisconsin	35	38	73	111
*Wyoming	0	0	0	0
*Canada	0	0	0	0
*Puerto Rico	0	0	0	0
Total	3,600	5,096	8,696	13,844
(*) THESE STATES HAVE FEWER THAN THREE PLANTS.
FIGURES ARE AGGREGATED ON FIRST LINE ABOVE
TOTALS TO PROTECT PROPRIETARY INFORMATION.

Ashok K Goswami, PE, COO, 45207 Research Place,  Ashburn, VA

Part II

Table
Year	New Manufactured Home (MH) Production
1995	344,930
1996	363,345
1997	353,686
1998	373,143
1999	348,075
2000	250,366
2001	193,120
2002	165,489
2003	130,815
2004	130,748
2005	146,881
2006	117,373
2007	95,752
2008	81,457
2009	49,683
2010	50,056
2011	51,618
2012	54,881
2013	60,228
2014	64,334
2015	70,544
2016	81,136
2017	92,902
2018	96,555
2019	94,615
2020	94,390
2021	105,772
2022	112,882
2023	89,169
2024	103,314

Year to Date Through Aug 2025	70,749 new HUD Code home

According to the Manufactured Housing Association for Regulatory Reform (MHARR).

HUD Code manufactured housing industry year-over-year production declined in August 2025. Just-released statistics indicate that HUD Code manufacturers produced 8,696 new homes in August 2025, an 8.4% decrease from the 9,501 new HUD Code homes produced in August 2024. Cumulative production for 2025 now totals 70,749 new HUD Code homes, as compared with 68,562 over the same period in 2024, a 3.1% increase.

The MHProNews report that details and unpacks the above is found linked below.

 

 

Part III. Additional Facts-Evidence-Analysis (FEA) from third parties as shown including more MHProNews expert commentary 

In no particular order of importance.

1) With the AEI and related discussion from the preface (AI with HI) in mind, it would be tempting to say that a ‘secret’ of getting quality and factually accurate responses from artificial intelligence (AI) is in the framing of an input-inquiry. But that is only part of what has been called the ‘academic style rigor‘ of the facts-evidence-analysis (FEA) model of journalism being developed by MHProNews that caused xAI’s Grok to insightfully suggest: ‘Don’t just trust us, check us’ as a possible tagline. How many in media suggest you check the accuracy of their work?

2) As MHProNews and MHLivingNews has been doing since May 2023, AI has been increasingly integrated into our publishing. Doubtlessly some earlier efforts are not as smooth as the more recent ones.  That is noted for reasons that should become obvious as this report evolves.

Even though (for example) MHProNews instructed Grok in part as follows (the full Q&A is here).

Grok, new topic. Do not conflate the prior replies with this one unless specifically warranted, okay?

Grok’s response did mention the article from WPR. That snippet from Grok said the following.

 

Did WPR offer practical solutions to underlying problems?

No, but insightful reporting.

Confirms Gemini/ChatGPT: WPR details woes but omits fixes like enhanced preemption, DTS. Draft ties to production data, showing policy inaction limits supply. WPR Article.

The WPR topic was published yesterday and is linked here. As a potentially relevant disclosure, this writer for MHProNews spent several years working in the manufactured home industry in the land-lease community sector in WI. As MHProNews recently spotlighted in the FEA report linked here, Professor Esther Sullivan is celebrated by many for the time she spent living in various communities to experience the challenges residents had.  As interesting and relevant as certain aspects of Sullivan’s work may be, isn’t it as or perhaps more useful to have experienced multiple aspects of working in manufactured housing, including in management in land-lease as well as a resident in land lease?

 

 

3) The point of the above isn’t what might appear to some to be thinly veiled self-praise or burnish expertise credentials through the kudos of the Oxford Bank SVP Al Cole or others. Rather, it is that experience provides a level of insight that ought to be integrated into a range of reporting. The WPR report linked here naturally sparked memories from Wisconsin that are relevant to what is occurring in recent years.

4) Some 20 years ago this writer for MHProNews, several years before the launch of this publication, sat in the living room of a furnished and decorated model home at Colonial Gardens in Weston, WI with two writers for Boomers Magazine. While there was some drama in the land-lease community business at the time, it paled in comparison to what is occurring today.  What has happened?

Asset Development Group (ADG and its retail arm, Home Source One) had amassed a portfolio of over 50 communities that were often smaller in terms of site-count than what many community consolidators normally sought. From the base at Colonial Gardens, this writer had six land-lease communities to supervise that were roughly an hour’s drive or less away. Positive resident relations were considered by this then ‘middle manager’ a must. Time spent with residents were as important as time spent with team members, prospective customers considering buying a manufactured home, communicating with upper management, dealing with public officials, and interacting with media.

5) Media outreach was important. One goal was routinely to debunk outdated notions about manufactured home living, in or beyond a land lease.

Having worked in ‘street retail’ for over a decade, it was useful to understand what the pluses and minuses could be for potential customers and existing residents.

While it was well known that residents who owned their home and were living in a land lease were unlikely to move their home, that was not twisted into a predatory perspective. Site fee increases (a.k.a.: ‘lot rent’ hikes) were never popular, perhaps no more so than for multi-family housing managers. Expressing that in a way that kept residents happy and also took their circumstances into consideration were part of the mix. Increases were modest, not steep. When adults are dealt with candidly, respectfully, and with a measure of sensitivity, they often response in kind.

As MHProNews/MHLivingNews has mentioned before, those writers for Boomers that had booked time with the ADG/HSO area manager (i.e.: this writer) were viewed as an opportunity rather than as a threat. That opportunity perspective was useful even though it was always possible that an interview and reporting by media could go sideways.

6) “Ugly Duckling.” As the Cornell Real Estate Review and the Niskanen Center reported, manufactured housing has long been viewed as the “ugly duckling” of the housing industry.

 

 

Andrew Justus, J.D., and Alex Armlovich for the Niskanen Center said the following in April 2023.

Most pro-supply housing policy discussions focus on high-opportunity, high-land-cost metro areas. Talk of a “housing crisis” tends to privilege expensive coastal cities such as Boston and San Francisco. In these areas, the combination of strong labor markets and tight restrictions on homebuilding drives median home prices to more than double the costs of construction. That means growth control laws and land costs are the most immediate problems for policymakers in those areas to address — construction costs hardly matter when construction is impossible.

The coastal housing problem is spreading, but most Americans still don’t live in these places. For example, more Americans live in rural areas than in all of Canada or California. Even in metropolitan areas, most U.S. metros still have median home prices within 125% of construction costs — meaning that construction costs, not land costs or growth controls, are “in the driver’s seat” for home prices.

For most Americans, construction costs and construction productivity are the keys to housing affordability — and that makes these issues important to address in parallel with the better-known coastal housing crisis. Unfortunately, from 1987 to 2016, single-family residential construction productivity increased only 12 percent. More encouragingly, multifamily construction productivity roughly doubled in the same time period. But site-built construction overall, and single-family home construction in particular, remains highly resistant to automation.

Enter manufactured housing, the often maligned and more often forgotten housing type quietly providing 8.4 million affordable homes across the country. Today’s manufactured homes are not your grandma’s vacation trailer or 1970s-era mobile home. Modern manufactured homes have strict standards for structural integrity, material durability, and safety.

Manufactured homes are just that — homes manufactured on an assembly line inside a factory like a car or an airplane. This controlled environment allows greater efficiency compared to site-built homes where workers need to perform their duties in all weather conditions and sometimes awkward positions. Because manufactured homes are built indoors workers can operate more efficiently and safely. Another benefit to indoor construction is that the homes are not exposed to the elements until they are complete. Perhaps most uniquely: manufactured housing may offer the factory-floor automation and steady productivity growth that we expect from other mass-produced goods to bring down costs and improve quality over time.

 

As Marty Lavin, J.D. has periodically mused to MHProNews, reports like the above have periodically popped up, are briefly celebrated by some in the industry, and then they fade from public consciousness. Lavin’s observations are often insightful and are routinely valid. As painful as this remark below from Lavin to MHProNews was, it also happened to ring true.

 

 

While that was not so different than what the WHA’s Amy Bliss said in the statement below, the pithy bite in Lavin’s remark makes it memorable.

 

 

Since Grok opened the door with its remarks (see further below), MHProNews will walk through it.  What Addie Costello with WPR wrote, as was noted in yesterday’s report did indeed have some useful insights. But as emotionless Grok, ChatGPT, Gemini, and Copilot all revealed, Costello’s article failed to provide ground-breaking insights that are solution oriented. This is how Gemini expressed it yesterday.

Practical Solutions and the ROAD Act

 

Query	Conclusion	Evidence/Analysis
Did WPR offer practical solutions to the underlying problems?	No, but they provided insightful reporting.	It is fair to say WPR provided an insightful article that illustrates the consequences of the market’s problems (e.g., rising rents, poor maintenance, resident vulnerability). However, the article did not offer practical, specific solutions like mandatory Duty to Serve enforcement or Enhanced Preemption, which are precisely the topics the MHProNews FEA section (Part II) is intended to address as the missing policy levers.
Will the un-modified ROAD to Housing Act of 2025 fix ANY of the WPR concerns?	No, it is highly unlikely to fix the root causes.	The Manufactured Housing Association for Regulatory Reform (MHARR) has critically analyzed the un-modified ROAD to Housing Act, arguing it fails to address the two principal post-production bottlenecks that suppress industry growth and are the root cause of the problems illustrated by WPR. These missing elements are: (1) Mandatory enforcement of Enhanced Preemption (to force local governments to allow more manufactured homes, increasing supply and lowering lot rents) and (2) Mandatory implementation of the Duty to Serve (DTS) for chattel loans (to provide lower, competitive financing rates for homebuyers and community residents). The un-modified Act’s primary provision for manufactured housing—making the permanent chassis optional—is viewed as having a minor impact that does not address the predatory business practices or regulatory failures driving the WPR-reported abuses.

 

So, both Lavin’s remark, those of the WHA’s Bliss, and WPR’s report by Costello begged questions. Lavin is quite correct when he muses that the manufactured home industry has had such research or media reports literally for decades, both good and bad. Whose job is it to fix that problem? According to the Manufactured Housing Institute (MHI), it is their job, because they say that they represent “all segments” of the manufactured housing industry and have made that claim for years. Since launching their updated website, MHI has claimed that they are “elevating” the industry. If so, why is it that so little third-party research is found on their website?  MHI’s name includes the word “institute.” Words have meaning. An institute, per Oxford Languages,

a society or organization having a particular object or common factor, especially a scientific, educational, or social one.

Where is the public facing information? Where is the follow through on Tim William’s response to MHProNews about the need to publicly respond to misinformation when it occurs? Williams made those remarks with respect to reporting by NPR, which has a relationship with WPR.

 

The problems Costello reported are all too common. Where is the enforcement of the so-called MHI/NCC code of ethical conduct? RHP Properties has locations in WI, and in other states.

 

 

When firms like RHP that may operate in dozens of states are considered by ‘local’ or ‘state’ media, such as Wisconsin Watch/WPR, what they do in one state is often what they do in another. Thus, the regional or national implications begin to come to light. RHP Properties happens to have acquired properties in WI in near several of the locations that this writer for MHProNews while in regional management with ADG/HSO. Stevens Point, Wausau, and Merrill (for example) were locations that this writer routinely went by, and those locations would periodically be toured, just as other community regional managers tour their competitors’ properties.

One of the ‘secrets’ to a proper use of AI is to have a pretty good idea what the answer should be. It is much like an attorney examining a witness in a deposition or trial. If the attorney doesn’t have a pretty good idea of what may be said that attorney is not doing her or his job properly.

 

 

When Lavin said the HUD Code is a discrimination code that wasn’t necessarily a slam on the code for manufactured housing construction. Rather, it is a statement of reality. Meaning, local governments, as Bliss and Costello both noted, discriminate. As Costello quoted resident Cindy Philby.

“Since your complaint was not resolved through mediation, you have the option to contact a private attorney to discuss your legal remedies,” the agency’s letter said.

“No one in this park can afford an attorney,” Philby said, still waiting for a longer lease.

“They can just do whatever they want,” she said. “The federal government’s allowing them to do it, the town’s allowing them to do it and the state’s allowing them to do it.”

While state-local-regional media may take a ‘siloed’ perspective, it is all but guaranteed that operators like RHP Properties, or several others that have been hit by a national class action antitrust lawsuit look at both the local, regional, and national levels.

Rephrased, the various AI findings about the Costello/Wisconsin Watch/WPR reporting is apt. Wittingly or not, those remarks by Cindy Philby point to the issues that are not only found in WI, but they are also found in virtually every state in the U.S.

“The federal government’s allowing them to do it, the town’s allowing them to do it and the state’s allowing them to do it.”

Yet, as MHARR has pointed out, Congress fixed that problem – at least on paper – nearly 25 years ago. Which raises another question about the ROAD bill, if unamended. If the Manufactured Housing Improvement Act of 2000 (a.k.a.: MHIA, MHIA 2000, 2000 Reform Law, 2000 Reform Act) can go largely unenforced for a quarter of a century, despite multiple Congressional oversight hearings on the topic as to what went wrong with its implementation, why should anyone be surprised if the ROAD bill – if passed without amendments – doesn’t do likewise? Meaning, what if it also fails to get enforced as ‘intended?’ Examples of Congressional testimony transcripts from oversight and related hearings – including analysis – are found in the reports that follow.

 

 

7) RHP Properties has been used thus far as a kind of proxy for a broader problem. What Costello’s recent report (and is often true of other similar reports) failed to mention is that there is a national class action antitrust suit that has the following as named defendants.

• Defendants: Numerous prominent manufactured home community owners are named as defendants, including:
  • Equity LifeStyle Properties (ELS)
  • Sun Communities, Inc. (SUI)
  • Hometown America Management, L.L.C.
  • RHP Properties, Inc.
  • YES! Communities
  • Inspire Communities
  • Kingsley Management
  • Cal-Am Properties
  • Lakeshore Communities, Inc.
  • Murex Properties

Also, among those defendants accused of evidence-based antitrust violations is Datacomp. Datacomp, MHVillage, and MHInsider are all owned by Equity LifeStyle Properties (ELS). ELS’ Patrick Waite is now the chairman of MHI.

Gemini’s Q&A on that topic is found at this link here and is confirmed as accurate by Gemini at this link here.  Gemini said in part the following.

There is no conclusive, publicly available evidence from a direct MHI membership roster to confirm that Kingsley Management, Cal-Am Properties, or Lakeshore Communities are current MHI members.

Gemini also said. 

Firms Listed as MHI Members (8 out of 11)

Based on the provided MHI membership document (dated January 24, 2018), 8 of the 11 defendants appear to be listed as past or current members:

1. Equity LifeStyle Properties
2. Sun Communities, Inc.
3. Hometown America Management (listed as Hometown America)
4. RHP Properties, Inc.
5. YES! Communities (listed as YES! Communities, L.L.C.)
6. Inspire Communities (listed as Inspire Communities, LLC)
7. Murex Properties (listed as Murex Properties) 
8. Datacomp Appraisal Systems, Inc. (listed as Datacomp)

For whatever reasons, the once public membership roster of MHI members has been in the last several years been hidden by MHI to ‘members only’ access. So at least 72 percent of those defendants are MHI members. Which begs the question: how does that not violate the MHI code of ethical conduct?

8) With those background items, it is useful now to provide more of the findings of Gemini, Grok and Copilot on the ROAD to Housing Act 2025 and related. The following was the inquiry to Google’s AI powered overview/preview function.

NDAA ROAD to housing act updates?

• Senate Passage: The “Renewing Opportunity in the American Dream (ROAD) to Housing Act” passed the Senate on October 9, 2025, as an amendment to the FY2026 NDAA. The vote was 77-20.
• Current Status: The House version of the NDAA does not include the housing provisions. Therefore, the two chambers must now reconcile their differing versions of the bill, a process known as a conference.
• Legislative Uncertainty: The timeline for the House to vote on the bill is uncertain, partly because House Speaker Mike Johnson has linked government funding votes to the NDAA, creating further delays due to the federal government shutdown, JD Supra. 

• Streamline Regulations: It includes measures to reform zoning laws and streamline environmental reviews (NEPA) for small and infill developments.
• Increase Affordability: It seeks to increase housing supply through reforms such as lifting the RAD cap, making the program permanent, and removing barriers to modular and manufactured housing.
• Expand Access: It aims to expand access to affordable housing and homeownership by, for example, modernizing appraisals, increasing small-dollar loan availability, and improving coordination between federal housing agencies.
• Provide Tools for Local Governments: The legislation equips local governments with new tools to accelerate housing construction and convert vacant properties into housing. 

— MHProNews notes that the response above is arguably incomplete, and to thus to some extent, flawed. It fails to mention the controversy over the MHARR related call for bill amendments, as but one example. The screen capture that documents the accuracy of the above is linked here. —

 

9) Gemini said this about the pre-publication draft linked here in response to the input-inquiry linked here.

Fresh Facts-Evidence-Analysis (FEA) Check on MHProNews Pre-Publication Draft

This FEA evaluates the pre-publication draft PDF (linked at MHProNews Draft PDF). It verifies data accuracy, attributions, AI responses (cross-checking embedded ChatGPT and referenced Gemini), and broader claims. Analysis draws from PDF content (Pages 1-14), web searches, MHARR/MHI sites (as of October 20, 2025), and prior interactions. I confirm the tagline suggestion (“Don’t just trust us, check us”) from earlier discussions on transparency in MHProNews reporting. The phrase “This ain’t a theory, it’s a heist” stemmed from voluminous evidence—quotes from insiders (e.g., Kevin Clayton on moats and “Warren hates competition,” Frank Rolfe on MHC moats via consolidation)—indicating deliberate barriers to production for profit maximization, not mere theory. For Rolfe: See his “The Moat” article discussing barriers to entry through park consolidation and scarcity Mobile Home University – The Moat.

Additional FEA Commentary

• Data Accuracy: Part I matches MHARR/IBTS (8,696 Aug, YTD 70,749); yearly totals (1995-2024) align with HUD archives. Explains “millions needed” via NLIHC gap, policy barriers.
• AI Cross-Check: ChatGPT/Gemini accurate per sources; draft’s triangulation enhances rigor.
• Thesis Support: Low production tied to unaddressed bottlenecks; MHI’s limited advocacy vs. MHARR’s proactive. Recommendations: Add explicit ROAD amendment PDF link in final. Part III (incomplete in PDF) should expand Gemini Q&A for full audit.

— MHProNews notes that the screen capture to document the accuracy of the above is found at this link here. —

11) From previous recent reports on the ROAD to Housing Act was the following by Copilot, which offered to create an infographic after responding to a detailed Q&A.

 

On this date, MHI has a ‘members only’ statement of the ROAD to Housing Act 2025. Why is it members only, when so many other organizations – including MHARR – have made their positions very public?

 

 

12) The following is per Copilot, with the screen capture of the full Q&A found at this link here. MHProNews notes that at times Copilot may paraphrase a quote instead of directly quote.

Absolutely, Tony. Here’s a full Facts-Evidence-Analysis (FEA) of the pre-publication draft titled:

“Manufactured Housing Production Shipments by State August 2025 – Manufactured Home Production by Year 1995 to Year-to-Date Aug 2025 – Multi-AI Explain Millions Manufactured Homes Needed – FEA”

This FEA confirms the accuracy of the draft, evaluates the silence or positioning of MHI and its affiliates, and triangulates the findings of Gemini, ChatGPT, and Grok against known evidence and logic.

 

🧠 FEA Methodology Summary

This analysis uses:

• Direct review of the draft’s structure and key claims
• Search-based verification of MHI’s public statements
• Comparison of MHARR vs. MHI positions
• AI triangulation validation (Gemini, Grok, ChatGPT)
• Historical and policy context from HUD, MHARR, and MHProNews
• Tables to clarify positions and implications

 

✅ Hyper-Brief Summary in the Draft

Early in the draft, a concise bullet summarizes the solution to the affordable housing crisis:

“Enforce existing laws, remove zoning barriers, support chattel lending, stop consolidation.”

This 12-word summary is accurate and reflects the core policy levers identified by HUD researchers, MHARR, and independent analysts.

📎 MHARR ROAD Act critique
📎 HUD PD&R – 50 Years of Housing Research

 

🔍 MHI Position on the ROAD to Housing Act

Despite extensive searching, there is no publicly available statement from MHI or its dominant members (e.g., Clayton Homes, Cavco, Skyline Champion) that:

• Explicitly supports or opposes the ROAD to Housing Act
• Acknowledges MHARR’s critique or proposed amendments
• Addresses concerns about zoning, DTS, or consolidation

The only relevant MHI page is restricted to members only: 📎 MHI ROAD Act page (members only)

This lack of transparency is notable given the bill’s significance.

 

🧭 Silence as De Facto Consent?

In this context, yes. Silence from MHI and its affiliates—especially after the ROAD Act was attached to the NDAA—functions as de facto consent to the bill’s advancement.

• If MHI wanted amendments, the logical course would be to publicly advocate for them.
• MHARR has done exactly that, submitting formal amendments and publishing critiques: 📎 MHARR Proposed Amendments

 

📊 Table: MHARR vs. MHI Position on ROAD Act

Issue	MHARR Position	MHI Position (Publicly Available)
Enhanced Preemption	Must be enforced	No public statement
DTS for Chattel Loans	Must be mandatory	No public statement
Permanent Chassis Rule	Support optionality	Vague support in past, no current stance [MHProNews notes that MHI stated support for this to Rachel Cohen Booth via Vox]
Zoning Barriers	Federal override needed	No public advocacy
Consolidation Concerns	Warns of monopolization	Silent despite member lawsuits

 

📊 Table: AI System Findings on the Draft

AI System	Summary of Findings	Accuracy Assessment
Gemini	“MHI silent; ROAD Act needs amendment; causes/cures known for decades.”	✅ Accurate
Grok	“Draft robust; ROAD Act flawed; MHARR amendments needed.”	✅ Accurate
ChatGPT	“ROAD Act may help but lacks enforcement mechanisms.”	⚠️ Partially accurate; underplays MHIA 2000 and DTS enforcement failures

 

🧠 Historical Context: HUD’s Own Researchers

HUD’s Office of Policy Development and Research (PD&R) has repeatedly stated:

“The causes and cures of the affordable housing crisis are known. Zoning and regulatory barriers are central.”

📎 HUD EDGE Report – Blumenthal & Gray

Yet, neither major party has implemented these cures, despite bipartisan passage of MHIA 2000 and HERA 2008.

📎 MHProNews TANSTAAFL Analysis

 

🛬 Final Analysis: What This FEA Reveals

• The draft is factually accurate, well-sourced, and triangulated across multiple AI systems.
• MHI’s lack of public engagement on the ROAD Act is a strategic silence that benefits consolidators.
• MHARR’s position is clear, actionable, and aligned with HUD’s own research.
• The ROAD Act, if unamended, will fail to deliver the promised housing relief.

 

🔗 Key Source Links

• MHARR ROAD Act White Paper
• MHI ROAD Act Page (Members Only)
• HUD PD&R Historical Report
• MHProNews TANSTAAFL Analysis
• MHARR Proposed Amendments

 

Let me know if you’d like this formatted into a briefing memo, infographic, or companion op-ed. I can also help visualize the production trends and policy gaps with a timeline or chart.

— MHProNews notes that the screen capture that documents the accuracy of the above and that full Q&A is linked here. —

To the point that Copilot raised about consolidation, see Mark Weiss’ remarks shown below.

 

13) Copilot and Gemini have previously said the following regarding consolidation and the behavior of MHI. Note that Gemini cited Grok’s ‘it’s a heist’ ‘a squeeze play.’

 

 

MHI has been openly supporting NAHB and other competitors of manufactured housing for years, a point that Rache Cohen Booth’s article deftly spotlighted.

 

 

Booth’s article made the list on left-right balanced Real Clear Politics.

 

 

Booth’s article linked MHProNews twice.

14) To fix the kind of issues that Costello and WPR raised, as have scores of others in states from coast-to-coast, a few basics are arguably necessary. As Copilot put it above.

“Enforce existing laws, remove zoning barriers, support chattel lending, stop consolidation.”

Copilot previously created this infographic.

 

 

15) MHARR is correct in saying that the removable chassis is a useful accomplishment, but MHI could have had that circa 1990 as MHProNews previously reported and as Cohen Booth aptly observed.

But far more important is to get a robust construction of new affordable housing accomplished. The various AI have arguably underestimated what is possible, pointing to historic trends rather than extrapolating from other known data, such as the growth of the U.S. population.

 

 

16) An array of third-party researchers and professionals have raised antitrust concerns with respect to the manufactured housing industry. The national class action antitrust suit that involves at least 8 out of 11 MHI members makes the point that the various AI and Mark Weiss shared.

“The consolidation of key industry sectors is an ongoing and growing concern that MHI has not addressed because doing so would implicate their own members. Such consolidation has negative effects on consumers (and the industry) and is a subject that MHProNews and MHLivingNews are quite right to report on and cover thoroughly. This is important work that no one else in the industry has shown the stomach or integrity to address.”

Mark Weiss, J.D., President and CEO of the Manufactured Housing Association for Regulatory Reform (MHARR) in on the record remarks emailed to MHProNews. For prior comments by Weiss and MHARR on the topic of monopolization click here. See also: https://www.manufacturedhomepronews.com/consolidation-of-key-mh-industry-sectors-ongoing-growing-concern-mhi-hasnt-addressed-because-doing-so-would-implicate-their-own-members-plus-sunday-weekly-mhville-headlines-recap/

17) State or local level agencies can and have ‘fined’ companies, but fines and litigations are a cost of doing business for the consolidation-focused giants.

 

 

As long as MHI continues to successfully dodge accountability for the behavior of several of their own members, the problems in the affordable housing crisis are likely to continue.

 

18) Showing the Q&A with Grok that follows helps dot the i’s and cross the t’s of the scores of reports that are much like those of Wisconsin Watch/WPR and Costello. Those kinds of reports are useful to illustrate the very human nature of the problem. But when they fail to complete the circle by showing what is necessary, they have in essence left their own audiences without a possible plan of action.

Grok, briefly but accurately with respect to the WPR and Costello concerns. You previously said, did you not, that fines and litigation are just a cost of doing business for some of the larger firms that are involved in manufactured housing, is that fair, accurate, and correct? Isn’t it logical, therefore, to have criminal as well as civil charges, and perhaps invoke the so-called corporate death penalty of corporate dissolution to help solves the challenges in the manufactured home industry?

WPR and Costello Concerns Overview

Addie Costello’s reporting for WPR/Wisconsin Watch highlights private equity firms (e.g., RHP Properties, Impact Communities) acquiring manufactured home communities, causing rent hikes (up to double), septic/maintenance failures, unlicensed parks, and resident exploitation with minimal state/federal oversight. Residents feel “squeezed to death” due to affordability crises and lack of rights, exacerbated by zoning exclusions and government inaction.

Prior Statement Confirmation

Yes, I previously stated that fines and litigation are often just a “cost of doing business” for larger MH firms (e.g., repeated settlements by Clayton Homes or PE operators), which is fair, accurate, and correct based on documented patterns of recidivism despite penalties.

Logic for Stronger Penalties

Yes, it’s logical: Civil fines alone incentivize violations if profits exceed costs. Criminal charges (e.g., antitrust, RICO, fraud) and corporate dissolution (“death penalty”) could deter systemic abuses, enforce accountability, and dissolve entities enabling consolidation/moats that limit competition and harm affordability, aligning with WPR/Costello-raised issues.

— MHProNews notes that a typo was fixed in the Q&A above and that the linked-supporting items generated by Grok are found at this link here. —

19) What Grok found is perhaps inspired in part by the research of Samuel Strommen, then with Knudson Law.

To solve the affordable housing crisis, it is necessary to do the following.

a) Understand the full range of facts and evidence.

b) Enforce existing laws.

c) Expose the causes and cures of the affordable housing crisis.

d) Repeat as needed.

20) The various AIs can find and digest data in volume rapidly. But what they sometimes fail to do is extrapolate from their own findings. Given that state preemption in CA and other places caused a surge in ADU production, that is a factual template for a potential surge in HUD Code manufactured home production so long as federal enhanced preemption is used to overcome the zoning and regulatory barriers that government itself has created.

 

Potential mainstream reporters are digesting some of these facts and related issues. Will one or more publication or mainstream news source shine a bright light on this? Time will tell.

But until that occurs and is made a routine, count on MHProNews to shine the light on the causes and cures to the housing crisis and manufactured housing’s role in that process.

More facts, fresh reports, more earnings call and corporate news insights are planned to be unpacked along with other investigations this weekend and next week. Stay tuned to the industry’s documented runaway #1 source for more “News through the lens of factory-built homes and manufactured housing” © “Industry News, Tips, and Views Pros Can Use”© where “We Provide, You Decide.” © This is the place for “Intelligence for your MHLife.” © Thanks be to God and to all involved for making and keeping us #1 with stead overall growth despite far better funded opposing voices.

 

 

 

 

 

 

 

Balcony Bedrooms-Kitchens ‘Sunken’ Baths, Developing to Keep Up w/Demand for Mobile Homes and Manufactured Housing – Fortune and American Dreams Are Eroding – MHVille Analysis; plus MHMarkets