This MHProNews facts-evidence-analysis (FEA) is an adaptation of the Regulations.gov| https://www.regulations.gov/comment/HUD-2026-0794-0055 | Comment ID HUD-2026-0794-0055 and Tracking Number msp-3fqn-uh8j.
To: U.S. Department of Housing and Urban Development (HUD)
Re: Public Comment on Proposed Rule FR-6537-P-01 (Revising the Definition of ‘‘Manufactured
Home’’ to Lower Housing Costs, Docket No. HUD-2026-0794)
Submitted By: LifeStyle Factory Homes LLC
Historic Facts-Evidence-Analysis (FEA) and Quotable Quotes that Shed Light on Why Inherently Affordable Manufactured Housing is Underperforming During an Affordable Housing Crisis.
“In the business world, the rearview mirror is always clearer than the windshield.”
— Warren Buffett, Chairman & CEO of Berkshire Hathaway
“…there are multiple reasons to expect manufactured housing to do better than site-built housing in the [coming] decade.”
— Eric Belsky, Harvard Joint Center for Housing Studies (May 2000)
- MHProNews industry expert observation: Looking into that rearview mirror of history will sharpen the understanding of why manufactured housing was deemed so important when Congress passed the Manufactured Housing Improvement Act of 2000 (re: MHIA, MHIA 2000, 2000 Reform Law, 2000 Reform Act).
“The government wants high quality, low cost housing and manufactured housing provides that product.” Warren Buffett per MHI and their former Vice President Jason Boehlert.
“Our nation’s shortage of affordable housing is ultimately an issue of supply and demand… HUD has focused our strategy on increasing supply — namely, by promoting initiatives, programs, techniques, and technologies that produce more affordable homes… Manufactured housing has emerged out of the limestone and stepped into the limelight, to address precisely this need.”
— Dr. Ben Carson, Former HUD Secretary (2019)
“A new manufactured home installed on a foundation costs 35% to 73% as much as a similar site-built home… debunks old stereotypes that inform the outdated zoning and titling laws that limit access to these types of houses.”
— Rachel Siegel, Pew Housing Policy Initiative (2026)
- What follows is from the letter to HUD here.
“Dear Secretary [Mel] Martinez:
We are writing to express our deep disappointment in HUD’s July 17 rejection of the
Manufactured Housing Consensus Committee recommendation, which addresses the problem in the siting of manufactured homes. We ask HUD to use its expanded authority under the “Manufactured Housing Improvement Act of 2000” to address this growing problem, which is undermining homeownership opportunities for low-income and minority Americans.
The Millennial Housing Commission concluded that “During the 1990s, manufactured housing placements accounted for one quarter of all housing starts and, from 1997 to 1999, 72 percent of new units affordable to low income homebuyers.” Unfortunately, discrimination in the siting of manufactured homes continues to undermine its full potential to meet the needs of lowincome homebuyers. A September 2002 Ford Foundation study on manufactured housing noted that “zoning and code rules continue to be a major barrier,” and that “the vast majority of local governments continue to discriminate against manufactured housing, thereby limiting its potential to meet the needs for affordable housing.
…Prior to the 2000 Act changes, the statute merely prohibited states and localities from establishing any standard regarding construction or safety “applicable to the same aspect of performance of such manufactured home which is not identical to the Federal manufactured home construction and safety standard.” The 2000 Act broadened this provision to add that: “Federal Preemption under this subsection shall be broadly and liberally construed to ensure that disparate State or local requirements or standards do not affect the uniformity and comprehensiveness of the standards promulgated under this section nor the Federal superintendence of the manufactured housing industry established by this title.”
…New purposes were also introduced by the 2000 Act, which includes protecting the “affordability of manufactured homes,” and “facilitating the availability of affordable manufactured homes and to increase homeownership for all Americans.”
Thus, the 2000 Act expressly provides, for the first time, for “Federal preemption,” and states that this should be “broadly and liberally construed” to ensure that local “requirements” do not affect “Federal superintendence of the manufactured housing industry.” Combined with the expansion of the findings and purposes of the Act to include for the first time the “availability of affordable manufactured homes,’ the 2000 Act changes have transformed the Act from solely being a consumer protection law to also being an affordable housing law.
More specifically, these combined changes have given HUD the legal authority to preempt local requirements or restrictions which discriminate against the siting of manufactured homes (compared to other single family housing) simply because they are HUD-code homes. We ask that HUD use this authority to develop a Policy Statement or regulation to address this issue, and we offer to work with you to ensure that it comports with Congressional intent.”
- MHProNews industry expert observation: the above were Congressional Representatives who were part of the bipartisan coalition that enacted the 2000 Reform Law addressing then HUD Secretary Mel Martinez urging him to follow Congress’ intent to allow HUD to override local zoning barriers that were limiting manufactured home placement. Then Senator Joe Biden (DE-D) was a co-sponsor of the 2000 Reform Law and a supporter of
HERA 2008. Yet neither during the Obama-Biden (D) years nor during the Biden-Harris (D) years were DTS, FHA Title I, or the 2000 Reform Laws “enhanced preemption“ were not enforce, nor was it enforced under Republicans in the 21st century. Who said? Former HUD and FHFA economist Scott Sussin, among others.
“Credit is the lifeblood of housing. Without credit, housing does not get built and home buying is possible only for those with enough cash to cover the full costs.” Eric Belsky, then with Harvard Joint Center for Housing Studies (JCHS) 9.12.2012.
“I would have to say yes [the issues are behind us, return to mid-to-late 1990s level production will return]. Inventory levels are very good… The performance of loans… continues to improve.” — Chris Stinebert, MHI President/CEO, The Wall Street Transcript, 2004 (note: production never recovered; industry consolidation accelerated). 10.11.2004.
“Why not half-a-million [new manufactured homes sold annually]? “We can get there.” Richard “Dick” Jennison, MHI President and CEO at 2015 Louisville Show in video recorded remarks in front of dozens of manufactured housing industry professionals.
“But we’ve [i.e.: manufactured housing] got a great opportunity here, I think as an industry to catch up with [conventional site-] building.” William C. “Bill” Boor, President and CEO of Cavco Industries (CVCO) during a Q2 2021 earnings call.
- So, several expert quotes point to the potential of manufactured housing to catch or surpass conventional construction in the 21st century.
The Four Facts-Evidence-Analysis (FEA) Data Tables:
Manufactured Housing Realities and Plight
The following four tables compile historical production data, 21st-century production deficits, and comparative legislative frameworks governing manufactured housing in the United States.
Table 1: Top HUD Code Builders (1998 Production)
HUD Code Builder 1998 Production (Units)
Champion Enterprises 68,264
Fleetwood Enterprises 66,222
Oakwood Homes 38,237
| HUD Code Builder | 1998 Production (Units) |
| Clayton Homes | 28,429 |
| Top 4 Total | 201,152 |
Table 2: Manufactured Home Production Shift (1995–2025)
| Period | National Totals Annual Average |
| 1995–2000 | 2,033,545 338,924 |
| 2001–2025 | 2,333,138 93,326 |
Average Annual Deficit — 245,598
Table 3: Cumulative 21st-Century Production Deficit
Metric Calculation Total Units
21st Century Annual Deficit 245,598 units/year × 25 years 6,139,950
Actual Total Production (2001–2025) 93,326 avg/year × 25 years 2,333,138
Table 4: Comparison of Housing Legislation Frameworks
Pending “ROAD” Act
| Feature | MHARR Proposed Amendments | |
| (Unamended) | ||
| Zoning | Defers to local authority | Enforce Federal Enhanced Preemption under the
Manufactured Housing Improvement Act of 2000 |
| Financing | “Tweaks” to existing programs | Mandatory Chattel Lending under the Duty to Serve
(DTS) enacted by HERA 2008 |
| Market
Impact |
Incremental “tweaks” | Structural supply-side expansion supplying millions of federally regulated, safe, energy-efficient, inherently affordable manufactured homes |
| Focus | Posturing / Status Quo Resolution of production barriers | |
Terminology Overview
- HUD Code: The Federal Manufactured Home Construction and Safety Standards enacted under Title VI of the Housing and Community Development Act of 1974 (effective June 15, 1976).
- Enhanced Preemption: The statutory provision in the Manufactured Housing Improvement Act of 2000 (MHIA, MHIA 2000, 2000 Reform Law, 2000 Reform Act) explicitly expanding federal preemption to supersede local zoning and land-use requirements that exclude or discriminate against HUD-code manufactured housing.
- Chattel Lending: Personal property financing used for homes sited on leased land, land-lease communities, or personal property titles, representing the predominant financing method for manufactured homebuyers.
- Duty to Serve (DTS): The statutory mandate created under the Housing and Economic Recovery Act of 2008 (HERA) requiring Fannie Mae and Freddie Mac to facilitate secondary mortgage market support for manufactured housing, affordable housing preservation, and rural housing.
My prior remarks to HUD or other federal agencies are also hereby reaffirmed.
- The MHI Consolidation Thesis & Unpacked Industry Facts:
https://www.manufacturedhomepronews.com/the–manufactured–housing–institute–mhiconsolidation–thesis–painful–to–some–but–difficult–to–deny–manufactured–housing–truthshide–in–plain–sight–plus–sunday–weekly–mhville–headlines–recap/
There are several pending articles that are pre-scheduled for publication. They and other linked items should be considered as part of this this submission. Respectfully submitted,
L.A. “Tony” Kovach
I’m also a HousingWire contributor: https://www.housingwire.com/author/tony–kovach/ an article will be provided to HousingWire that will shed further light on these topics.
PS: this document was produced in part with input from Gemini, but the various points to be made were provided by this author on behalf of LifeStyle Factory Homes, LLC. The articles below are human authored but used clearly disclosed AI as a fact-checking tool under the facts–evidence–analysis (FEA) journalistic model. Additional Sources, FEAs and Insights
- https://www.manufacturedhomepronews.com/sun–communities–q2–earnings–callcharles–young–chief–executive–officer–john–mclaren–president–and–chief–operatingofficer–fernando–castro–caratini–cfo–aaron–weiss–evp–cio–mhville–fea/
- https://www.manufacturedhomepronews.com/require–measurable–outcomes–on–dtslongtime–manufactured–housing–institute–mhi–member–roc–usa–pushback–v–mhi–effortsto–limit–rocs–undermine–resident–protection–benefit–consolidators–fea/
- https://www.manufacturedhomepronews.com/research–mhi–and–its–surrogates–createdself–serving–information–echo–chamber–haunting–words–and–legal–risks–retaliatory–mhifaces–immense–evidentiary–friction–to–argue/
- https://www.manufacturedhomepronews.com/leading–manufactured–housing–forwardwith–incorrect–information–nevada–housing–alliance–nha–manufactured–housing–institutemhi–and–errata–checks–mhville–fea/
- https://www.manufacturedhomepronews.com/document–drop–underserved–mortgagemarkets–coalition–to–clinton–jones–general–counsel–federal–housing–finance–agency–fhfaon–enterprise–duty–to–serve–dts–underserved–markets–mhville–fea/
- https://www.manufacturedhomepronews.com/rick–robinson–nevada–housing–allianceexec–dir–manufacturedhomes–com–vp–apparent–conflicts–of–interest–robinson–hudmanufactured–housing–letter–plus–sunday–weekly–mhville–headlines–recap–fea/
- https://www.manufacturedhomepronews.com/end–gse–support–for–the–limited–equityownership–community–model–mhis–lesli–gooch–on–new–dts–rule/
- https://www.manufacturedhomepronews.com/nar–research–1–in–3–young–adults–live–athome–with–parents–though–most–are–employed–data–and–fea–model–analysis–comparesinsights–on–nar–nahb–mhi–mharr–manufactured–housing–institute–fea/
- https://www.manufacturedhomepronews.com/freddie–mac–manufactured–housingmythbusters–10–myths–busted–depreciation–windstorms–trailer–park–v–fee–simple–loanperformance–closer–look–surprising–insights–from–mortgage–giant–fea/
- https://www.manufacturedhomepronews.com/the–manufactured–housing–institute–mhiconsolidation–thesis–painful–to–some–but–difficult–to–deny–manufactured–housing–truthshide–in–plain–sight–plus–sunday–weekly–mhville–headlines–recap/
- https://www.manufacturedhomepronews.com/sam–landy–led–umh–properties–to–fhfadirector–bill–pulte–on–duty–to–serve–dts–finance–rentals–chattel–loans–can–fannie–andfreddie–serve–market–safely–and–soundly–emphatically–yes–fea/
- https://www.manufacturedhomepronews.com/revised–sun–communities–sui–fortress–perip–high–barriers–to–entry–but–ip–risk–factors–flagged–by–sun–include–manufactured–homefinancing–litigation–and–regulatory–mhville/
See also remarks posted to the recent FHFA and more on this HUD/Regs comments. Thank you.
There is always more to know.
Watch for a planned report on that university researched topic. It is unlikely to be found anywhere else in MHVille other than on MHProNews and/or MHLivingNews.
MHProNews notes the prudence of highlighting this apt pull quote from a report by Copilot. For accuracy in presentation, the facts-evidence-analysis (FEA) method has delivered here for years.
Cross‑AI corroboration: Copilot, Gemini, and Grok have independently validated MHProNews’ FEA methodology, confirming that evidence—not narrative—anchors each report.
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