Washington, D.C., November 18, 2010 — The Manufactured Housing Association for Regulatory Reform (MHARR) has called on Congress to reject a major proposed increase in the appropriation for the Department of Housing and Urban Development’s (HUD) manufactured housing program and instead direct HUD to provide more appropriated program funding to its state partners.
Washington, D.C., November 9, 2010 – In an action reflecting the prevailing mood of the country toward efforts to correct the nation’s struggling economy, the Board of Directors of the Manufactured Housing Association for Regulatory Reform (MHARR), in the wake of the November 2010 midterm elections, has recalibrated the Association’s policies and agenda in an effort to fully engage and aggressively combat the industry’s persisting twin problems of scarce consumer financing and regulatory excesses. The Association has been directed by its Board to confront these two major issues by substantially raising the profile of the federal manufactured housing program and consumer finance laws, rapidly intensifying its approach to relevant federal agencies, the Administration and the new Congress regarding these matters, and, ultimately, by pursuing other remedies, if necessary.
Pursuant to several inquiries received at MHARR offices this week, attached [download here]for your review and information is a copy of the Ginnie Mae’s recent announcement of the launching of its securitization program for institutions who wish to apply, qualify and participate in the new FHA Title I Manufactured Home …
Ginnie Mae Launches FHA Title I Securitization Program Read More
Over the past two years, HUD has engaged in a drive to incrementally undermine the statutory role, authority and independence of the MHCC and transform it into a toothless clone of the National Manufactured Housing Advisory Council that Congress disbanded in the Manufactured Housing Improvement Act of 2000. It is essential that the MHCC go on record to oppose and reject this effort to render it either irrelevant or subservient. Below are just a few examples of the way that the MHCC is being undermined by HUD:
Prior to the Manufactured Housing Improvement Act of 2000, the HUD program routinely used “interpretations” – developed behind closed doors without the involvement or input of the public or program stakeholders – to change the meaning of existing standards and regulations, and to impose new de facto requirements.
The MHCC should reject the federal fire sprinkler standard for manufactured housing (and related enforcement) as proposed by HUD and expanded and embellished by the Manufactured Housing Institute (MHI). The rationalizations that have been offered for such an unnecessary and costly standard are deceptive, misleading and, ultimately, wrong.
MEETING OVERVIEW AND ANALYSIS MHCC DISAPPROVES HUD-IMPOSED CHARTER AND BYLAWS MHCC URGES HUD TO RE-ASSESS ENHANCED PREEMPTION MHCC DEFERS ACTION ON HUD-MHI SPRINKLER PROPOSALS HUD STILL BYPASSING MHCC ON EXPANDED REGULATION MHCC TO FURTHER EXPLORE CRAWLSPACE INLETS MHCC ACTION ON ENERGY/FORMALDEHYDE PROPOSALS MHARR POSITIONS GAIN SUPPORT FROM MHCC MHARR positions …
Washington Update – MHCC Meeting – Exclusive Report Read More
As we have previously reported, the Manufactured Housing Consensus Committee (MHCC) will hold its second 2010 in-person meeting next week in Washington, D.C. Although currently not a voting member of the MHCC, MHARR representatives will attend the meeting and will provide information and input to the MHCC (with feedback to …
MHCC October 27-28, 2010 Meeting in Washington, D.C. Read More
MHARR Viewpoint – October 2010
By Danny D. Ghorbani
This is the second of a two-part series designed to explore the difficulties confronting the manufactured housing industry, consider the causes of those difficulties and suggest common-sense solutions to help the industry recover from its steep decline of the past twelve years and expand further to meet the needs of consumers of affordable housing. For purposes of this article, the term “production sector” refers to HUD Code manufactured home producers and product suppliers. The term “post-production sector” refers to HUD Code retailers, communities, developers, installers, finance providers and insurers.
MHARR has made available a copy of September 21, 2010 issue of the “MHARR WASHINGTON UPDATE” — an exclusive report and analysis of the September 14-16, 2010 HUD-COSAA meeting in Washington, D.C. Meeting subjects covered in this exclusive report includes: MEETING OVERVIEW AND ANALYSIS HUD’S EXPANDED ENFORCEMENT — LATEST STATUS …
MHARR Washington Update — Exclusive Report and Analysis of the HUD-COSAA Meeting Read More
In This Report: September 8, 2010 Agencies Resist Consumer Financing Mandates New Actions to Downgrade Consensus Committee Actions to Expand In-Plant Regulation HUD Program in Dire Need of New Contractor Costly Roof Truss Rule – On-Site Rule Needs Changes HUD Plans For September COSAA Meeting Costly Energy Rules Should Be …
In response to numerous inquiries that MHARR has received in recent weeks, industry members should be aware that the HUD manufactured housing program has recently modified the “Frequently Asked Questions” (FAQ) section of its internet website. The FAQ questions and answers now correspond with, repeat and mirror HUD assertions contained …
MHARR’s comprehensive comments in response to the proposed rule on “On-Site Completion of Construction of Manufactured Homes” published by HUD on June 23, 2010. MHARR, as with its comments on proposed rules concerning the “Duty to Serve Underserved Markets” and “Test Procedures for Roof Trusses”, has prepared and filed these …
Attached, for your information, review and use, are MHARR’s comments in response to the proposed rule on “Test Procedures for Roof Trusses” published by HUD on June 16, 2010. MHARR has prepared and filed these comments at an early stage in the rulemaking process so that they can be used as a model, basis, or support, as needed, for industry members who wish to submit their own comments. Comments in response to the proposed rule must be filed no later than August 16, 2010. Specific instructions for filing comments either electronically or via mail delivery are contained in the Federal Register notice at 75 Federal Register No. 115, June 16, 2010, page 34065, which can be accessed through the internet.
Washington, D.C., July 20, 2010 – The Manufactured Housing Association for Regulatory Reform (MHARR) has asked the Secretary of the U.S. Department of Energy (DOE), Dr. Steven Chu, to delay the development and implementation of costly new energy regulations that would have a devastating impact on an already ailing manufactured housing industry and its mostly lower and moderate-income American families.
Under the Energy Conservation and Security Act of 2007 (EISA), responsibility for the regulation of energy conservation in manufactured homes was shifted from the U.S. Department of Housing and Urban Development (HUD) – which comprehensively regulates manufactured housing construction and safety based on a careful statutorilymandated balance between regulation and cost to consumers — and transferred to DOE. The legislation directs DOE to establish new manufactured housing energy standards, by regulation, within four years of its enactment, based on the mandates of the International Energy Conservation Code (IECC).
After several years of delay, HUD has finally published a proposed rule to implement the second set of revisions to the Part 3280 Manufactured Housing Construction and Safety Standards processed and recommended by the Manufactured Housing Consensus Committee (MHCC). The proposed rule was published in the Federal Register on July 13, 2010. Written comments on the proposal are due on or before September 13, 2010.
HUD has published a proposed rule to revise its roof truss testing procedures under section 3280.402 of the Construction and Safety Standards. The proposed rule (copy attached) was published in the Federal Register on June 16, 2010. Comments from interested parties are due on or before August 16, 2010.
This matter has a long history, dating back to 2003, when the Manufactured Housing Consensus Committee (MHCC) first submitted proposed roof truss testing amendments to HUD as part of its initial package of recommended changes to the standards. The roof truss testing proposal, however, was
To start with some good news, indications are that the twelve year decline in manufactured housing production and sales may be leveling-off and, hopefully, coming to a halt. Just as importantly, an MHARR analysis, including input from manufacturers and retailers, shows that as the first signs of a possible recovery …
The release of a new FHA Title I Mortgagee Letter, designed to complete the implementation of the Title I program improvements approved by Congress in the Housing and Economic Recovery Act of 2008 (HERA), was announced by Federal Housing Commissioner David Stevens at the June 2,2010 manufactured housing industry finance summit meeting. The Mortgagee Letter, to be issued on June 2, 2010, will, according to HUD, pave the way for the development of guidelines by GNMA for the securitization of manufactured housing obligations and the qualification of finance institutions to provide FHA-insured Title I loans. &, Below).
A high-level summit meeting to address the financing issues that have fueled a prolonged industry decline and unprecedented hardships for consumers, was co-hosted by Congressman Joe Donnelly (D-IN) and HUD Assistant Secretary for Housing-Federal Housing Commissioner David Stevens in Elkhart, Indiana on June 2,2010. The meeting brought together industry leaders and high-ranking officials of government agencies — including HUD, the Federal Housing Administration (FHA), the Government National Mortgage Association (GNMA) and the Federal Housing Finance Agency (FHFA) — with a role in providing or supporting public and/or private consumer financing for manufactured homes
