“Badges of Fraud,” Graydon Law, Manufactured Housing Institute/Members, plus Manufactured Housing Investing, Stock Updates

DowJones12.10.2020ManufacturedHomeStockUpdatesBroaderMarketSnapshotEvan T. Miller, J.D., in an article whose title begins with the phrase “Badges of Fraud and the Imputation of Actual Fraudulent Intent,” noted in Case No. 08-11407 that the trial judge found that the evidence “contained sufficient “badges of fraud” for the Court to draw the “reasonable inference…” that the defendants had “the actual intent to delay, hinder, or defraud” in the case in question.

Another attorney wrote recently about the topic “badges of fraud” explained that ““badges of fraud[are] —telltale signs that a fraud has taken place—short of positive proof of the actual fraud, because fraudsters have a tendency of covering their tracks,” said Stephen B. Meister, J.D.

There are arguably numerous possible legal issues that could involve specific Manufactured Housing Institute (MHI) members, as well as current and some prior MHI staff.

America is in a well-documented affordable housing crisis. Despite the posturing, photo ops, videos, and emails patting themselves on the back, MHI and its leaders at this point in 2020 are behind on year over year (YoY) production/shipments of new HUD Code manufactured homes compared to 2019.



2019 was another YoY decline compared to 2018. Yet, manufactured housing has good federal laws that could be used to robustly grow the industry. MHI and their leaders are well aware of those federal laws, as the following letter to their outside attorney John Greiner at Graydon Law will aim to demonstrate.



On December 9, 8:48 AM, the following email was sent to that MHI outside attorney. The links and originals were in the original. This letter to their attorney will be followed by additional MHProNews information.


from:   L. A. Tony K
to:       John Greiner

Attn: John Greiner, Graydon Law, MHI Outside Attorney – Issues Reply Request


As a reminder to the attorneys and other select manufactured housing industry connected professionals or advocates in the BCC of this message, you advised MHProNews in writing that the Manufactured Housing Institute (MHI) was paying you and your firm to monitor our publications. Good for you.

You should therefore be aware of the fact that MHI member Cavco Industries, a publicly traded firm (Nasdaq:CVCO), has published statements reported by MHProNews that indicated their desire for more competitive home only lending. Their president and CEO William Boor as well as their investor relations presentation each have effectively made that point.

Furthermore, the report linked above and here also reflects Cavco’s statement to investors of the value of using manufactured homes as urban infill.

Additionally, MHI’s president and CEO for several years has signed IRS Form 990 under penalties of perjury. Those fillings indicated that MHI’s board of directors first reviewed and approved those IRS 990 documents before they were filed. They make the case that MHI’s mission is to grow the market for HUD Code manufactured homes.



Next, let’s recall that after months of being in the MHProNews and MHLivingNews spotlights for MHI’s purported failure to properly promote the favorable “enhanced preemption” clause of the Manufactured Housing Improvement Act (MHIA) of 2000, that Lesli Gooch issued a letter to HUD Secretary Ben Carson that included the points noted in the screen capture below from her letter. You no doubt have the full letter or can access it from Gooch, who is currently MHI’s CEO.



Despite those formal statements from MHI, an MHI member – Legacy Housing’s executive chairman Curt Hodgson – said in published statements earlier this year that manufactured housing has a “place to put” challenge.

MHI award-winner and MHI-affiliated Pennsylvania Manufactured Housing Association’s Mary Gaiski said that the zoning and placement issue is getting worse, not better. She is obviously not alone.


Our sources with MHI and on Capitol Hill have indicated that there is no record of a public, face-to-face request by MHI leadership to Dr. Carson to get the full and proper implementation of the MHIA 2000, especially its “enhanced preemption” clause.

> So, while Ms. Gooch sent that letter for MHI in July 2019, is there any evidence you can provide that HUD Secretary Carson ever read it?

> Is there any formal response by Dr. Carson on the issue Gooch raised that would indicate he ordered HUD’s Office of Manufactured Housing Programs (OMHP), and/or HUD’s General Counsel, to begin to legally back the “enhanced preemption” MHIA mandate?

1) MHProNews would hereby request a written response to those pressing questions.

Without belaboring the point, the above and what flows from linked reports should be sufficient to establish this reality. While MHI has pushed for Duty to Serve (DTS) lending by the Government Sponsored Enterprises (GSEs) of Fannie Mae and Freddie Mac for CrossModTM homes, that program is arguably a market failure, per published data and MHI member insights to MHProNews. If you have any data or statistical evidence of robust sales of MHI backed CrossModTM, that should be made public, don’t you think? Indeed, good or bad, shouldn’t that data be public, so that the association’s members can see how effective or not their 6 figures in associated costs have been?

2) Given that Boor and Cavco, among others at MHI, have made the case that competitive rates are fueling more demand for mainstream HUD Code manufactured housing, why isn’t MHI pressing for the full implementation of DTS using chattel loans originated by the GSEs?  Or is Tim Williams recent statement a reflection of a conflict of interest in getting the GSEs to fully comply with the law?



Please provide written responses to the above and what follows via email for our mutual accuracy in handling. Let us know who to attribute statements to, please.

We plan a report for our readers on these topics. These are hardly new issues or concerns for MHI, so kindly see to it that we get a prompt written response to these inquiries. Fair enough?


(Note the headline above is a literary device, which the report makes clear)


3) Finally, as the reports linked herein and below, or Cavco’s statements, and what flows from them have documented and indicated, MHI is still publishing on its own website self-contradictory and arguably inaccurate information. To Cavco’s credit, they have made some corrections. It does not take a lot of time to correct errors on one’s own website or brochures, if the proper information and motivation for correction exists.

Please advise once MHI has corrected their conflicting statements and errors on their own website.

Given that mainstream media quote claims made by MHI, which amplifies and/or perpetuates arguably misleading information, and because publicly traded firms may rely upon those MHI claims – thus possibly influencing investors – accuracy and consistency ought to be an issue of some importance to MHI. Don’t you agree?

We look forward to your replies. Thank you,


L. A. “Tony” Kovach
Managing Member
LifeStyle Factory Homes, LLC

MHLivingNews.com | MHProNews.com | LATonyKovach.com | …



The implications and logic from Cavco’s own words should underscore the need to fully and properly implement the MHIA 2000, and to fully and properly implement the DTS provision of manufactured home lending – particularly the “home only” or “chattel loan” lending – on mainstream manufactured homes.

After some 34 hours, neither MHI’s attorney(s), nor MHI leaders responded to the MHProNews inquires and requests to attorney Greiner at Graydon Law..

But does ducking or hiding prove them correct? As state association MHEC members – MHI affiliates – previously told MHProNews, if MHI had a good counter argument, they should make it publicly. That fact that they don’t quietly speaks volumes.

Why does this matter to manufactured housing professionals and investors? That will be our featured focus this evening.

For new readers, the featured focus follows thought provoking quotable quotes, today’s left-right headline recap, and two of the three market snapshots at the closing bell today. The manufactured housing market summary of publicly traded equities at the close today follow the featured focus and the linked recent/related reports.

To get our x2 weekly industry-leading emailed news headlines, click here.

 Quotes That Shed Light – American Social, Industry, National Issues…


During the Obama-Biden administration, MHI’s Jason Boehlert, by accident or design, let the proverbial cat out of the bag with this comment. He was later replaced by Lesli Gooch, who is now their CEO.



Understanding media bias is useful to sifting through possibly hidden agendas.


Headlines from left-of-center CNN Business

  • The Covid cliff
  • He’s almost 40 and earned a good living. Now he may have to move in with his mother
  • The market has rarely been this expensive — and nobody cares
  • Airbnb just debuted on Wall Street. Now it’s worth more than Marriott and Hilton combined
  • Analysis: No profits? No problem for red hot tech IPOs
  • The legal battle to break up Facebook is underway. Now comes the hard part
  • Melinda Gates: Vaccine ‘disinformation can equal death’
  • GE misled investors before its stock imploded, SEC says
  • Disney+ notches 86 million subscribers, showing off a wealth of new streaming content
  • What struggling homeowners need to know before the end of the year
  • Small businesses owners: Our livelihoods are at stake and Congress doesn’t seem to care
  • McDonald’s will be giving away free food throughout the holidays
  • Even stocking stuffers will look different for a Covid Christmas
  • This Startup is Disrupting the $28T Retirement Industry
  • Here’s what happened during SpaceX’s Mars prototype rocket test flight
  • In this screengrab, Taylor Swift performs onstage during the 55th Academy of Country Music Awards at the Grand Ole Opry on September 16, 2020 in Nashville, Tennessee. The ACM Awards airs on September 16, 2020 with some live and some prerecorded segments.
  • Taylor Swift released two albums in 2020. Most of us are just trying to get by
  • Ben & Jerry’s new Colin Kaepernick “Change the Whirled” ice cream.
  • Ben & Jerry’s creates Colin Kaepernick-inspired ice cream flavor
  • “SNAP/EBT Food Stamp Benefits Accepted” is displayed on a screen inside a Family Dollar Stores Inc. store in Chicago, Illinois, U.S., on Tuesday, March 3, 2020. Dollar Tree Inc. released earnings figures on March 4. Photographer: Daniel Acker/Bloomberg via Getty Images
  • Millions on food stamps can’t grocery shop online. Here’s why
  • Economist: It will take years for jobs to recover
  • 42% of Americans earn less than they did pre-Covid
  • Frustrated restaurant owner blasts shutdown
  • Why Americans need a stimulus deal in three stats
  • Georgia becomes ground zero for election misinformation
  • Parler’s explosive growth is over
  • Google will lift political ad moratorium
  • How social media sites are tackling vaccine misinfo
  • Social media bet on labels to combat election misinformation. Trump proved it’s not enough

Headlines from right-of-center Newsmax

  • CNN Reports Newsmax TV Beat Fox News for First Time in Ratings
  • States Respond to Texas’ Supreme Court Case: ‘Cacophony of Bogus False Claims’
  • Election 2020
  • Federal Judge Casts Doubt on Trump’s Wisconsin Lawsuit
  • AG Paxton: Texas Lawsuit Not Hoping to Put ‘Genie Back in the Bottle’
  • Trump Warned Georgia AG Against Push Back on Texas Lawsuit
  • Records Still Not Available for 500,000 Georgia Absentee Ballots
  • AG Moody: Supreme Court Should Review Texas Motion
  • Trump Keeps Hope of Victory Alive in Remarks Hanukkah Party
  • 17 States Join Texas Election Suit
  • The Trump Presidency
  • McConnell Signals No GOP Support for Emerging COVID-19 Deal
  • State Dept: Pompeo’s Wife Cleared of Travel Ethics Charges
  • McConnell Urges Passage of Defense Bill
  • Cotton Calls For Special Counsel To Investigate Hunter Biden
  • Mnuchin to Recommend Sale of $700M YRC Loan
  • Morocco Recognizes Israel, Wins Trump Nod on Western Sahara
  • McCarthy: Swalwell ‘Jeopardizing National Security’
  • Newsfront
  • Cotton: Appoint Special Counsel to Probe Hunter Biden
  • Tom Cotton, R-Ark., on Thursday called for the appointment a special counsel to investigate Hunter Biden. …
  • Related Stories
  • Fed Tax Inquiry Into Hunter Biden Examining Dealings With China
  • Finance
  • Jobless Claims Jump to Three-Month High Amid New Shutdowns
  • Applications for U.S. unemployment benefits surged last week, topping estimates with the highest level since September, suggesting that widening business shutdowns to curb the pandemic are spurring fresh job losses. [Full Story]
  • Mnuchin to Recommend Sale of $700M YRC Loan
  • CEO to Forgo Potential $112 Million Bonus to Back Wife’s Career
  • Last Chance to Cut Your Taxes: COVID-19 Breaks Lapse at Year-End
  • Breaking Up Facebook Would Be More Complicated Than It Sounds
  • Health
  • Why Vaccinated People Still Need to Wear a Mask
  • The COVID-19 vaccines from Pfizer and Moderna claim to be over 90 percent effective in preventing disease, but experts say you should still wear a mask even if you are inoculated.
  • Experts: COVID-19 Vaccine Does Not Cause Infertility in Women
  • Study: Heart Palpitations Common During Menopause
  • Study: Instagram Influencers Making Men More Body-Conscious
  • High-Dose Flu Shot No Better for Heart Patients

Market Indicator Closing Summaries – Yahoo Finance Closing Tickers on MHProNews…


Featured Focus –
Where Business, Politics and Investing Can Meet


Let’s keep this straightforward. Based on the email shown above to Graydon Law and known facts, the following points can be made.

  1. There is an affordable housing crisis.
  2. There are good federal laws that for whatever reason, once of which the Manufactured Housing Institute once worked with the Manufactured Housing Association for Regulatory Reform to enact. So why is MHI not pushing for the full implementation of good laws that would boost sales for all MHI members?
  3. There are several possibilities, among which is that key MHI members and MHI staff are working to keep the industry from growing. Who logically benefits from that pattern? Arguably it is consolidators, which several of MHI’s key members say that they are focused upon – Mergers and Acquisitions or “consolidating” the “fragmented” manufactured home industry.
  4. Given that Graydon Law’s John Greiner and key MHI member/leaders are aware of these issues, they arguably reasonably can not claim ignorance.
  5. Given that Graydon Law’s Greiner, along with other key MHI leaders, do not act, it suggests they are happy with the status quo.
  6. These examples are elements that make the case that manufactured housing is being rigged against the smaller businesses in the industry.

Even non-MHI members that are state association members should be outraged by this. Their dues – through the state – help support MHI too.

MHI and state association members are encouraged to reach out for possible lawful next steps. Say “MHI or State Association Member 12.10DBN” in the subject line.


Small business? State or MHI member? iReportMHNewsTips@mhmsm.com – Say “MHI or State Association Member 12.10DBN” in the subject line.


Since Buffett-led Berkshire bought Clayton, the industry is actually smaller today than then. How is that possible, during an affordable housing crisis, unless they wanted it to be so?


To see the manufactured housing equities snapshot at the close today, scroll beyond the linked recent and related reports.

Related, Recent, and Read Hot Reports

“DEFCON 1 for American Small Businesses” – COVID19 Lockdowns, JCN’s Alfredo Ortiz on “Operation Mayday” Threats to U.S. Small Businesses

“Bring That Demand Forward” – William “Bill” Boor, Cavco Industries CEO, What’s Next for CVCO and Manufactured Home Industry Growth, plus, Manufactured Housing Investing, Stock Updates

Mobile Homes, Manufactured Homes – Manufactured Housing Institute (MHI), Manufactured Housing Association for Regulatory Reform (MHARR), Modular Home Builders Association – MHInsider’s Media Researchers Resources

“Desperate” “BS” – ‘Las Vegas Casinos Don’t Like Card Counters’ – Cavco Industries “We Have a Great Opportunity” – Cavco Leadership Statements Highlight Bright Dark Spots

Warren Buffett’s “Moat” per Kevin Clayton, CEO Clayton Homes Interview Transcript, Video – Affordable Housing and Manufactured Homes

Manufactured Housing Industry Investments Connected Closing Equities Tickers

Some of these firms invest in manufactured housing, or are otherwise connected, but may do other forms of investing or business activities too.

  • NOTE: The chart below includes the Canadian stock, ECN, which purchased Triad Financial Services, a manufactured home industry lender
  • NOTE: Drew changed its name and trading symbol at the end of 2016 to Lippert (LCII).



Fall 2020
Berkshire Hathaway is the parent company to Clayton Homes, 21st Mortgage, Vanderbilt Mortgage and other factory built housing industry suppliers.
· LCI Industries, Patrick, UFPI, and LP each are suppliers to the manufactured housing industry, among others.
· AMG, CG, and TAVFX have investments in manufactured housing related businesses. For insights from third-parties and clients about our publisher, click here.
Enjoy these ‘blast from the past’ comments.

MHProNews. MHProNews – previously a.k.a. MHMSM.com – has celebrated our 11th year of publishing, and is starting our 12the year of serving the industry as the runaway most-read trade media.

Sample Kudos over the years…

Learn more about our evolutionary journey as the industry’s leading trade media, at the report linked below.

Correcting the Manufactured Housing Industry Record – Looking Back, Looking Ahead – Plus Manufactured Home Investing, Stock Updates

· For expert manufactured housing business development or other professional services, click here.
· To sign up in seconds for our industry leading emailed headline news updates, click here.

Disclosure. MHProNews holds no positions in the stocks in this report.


Evidence-Based State of the Manufactured Housing Industry, Fall 2020 Report – plus, Sunday Weekly Manufactured Home Headlines Review

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We recommend that news tips NOT use company, nonprofit or organizational emails or cell phones. To report a news tip, click the image above or send an email to iReportMHNewsTips@mhmsm.com – To help us spot your message in our volume of email, please put the words NEWS TIP or COMMENTS in the subject line.

That’s a wrap on this installment of “News Through the Lens of Manufactured Homes and Factory-Built Housing” © where “We Provide, You Decide.” © (Affordable housing, manufactured homes, stock, investing, data, metrics, reports, fact-checks, analysis, and commentary. Third-party images or content are provided under fair use guidelines for media.) (See Related Reports, further below. Text/image boxes often are hot-linked to other reports that can be access by clicking on them.)


By L.A. “Tony” Kovach – for MHLivingNews.com.
Tony earned a journalism scholarship and earned numerous awards in history and in manufactured housing. For example, he earned the prestigious Lottinville Award in history from the University of Oklahoma, where he studied history and business management. He’s a managing member and co-founder of LifeStyle Factory Homes, LLC, the parent company to MHProNews, and MHLivingNews.com. This article reflects the LLC’s and/or the writer’s position, and may or may not reflect the views of sponsors or supporters.



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