Chattel lending is crucial to the availability of affordable manufactured housing for American families, representing as much as 80% of consumer loans for the purchase of new manufactured homes.
Knowing this, Congress specifically included manufactured home chattel loans in the “Duty to Serve” provision of the Housing and Economic Recovery Act of 2008.
The total exclusion — thus far — of those loans from two proposed DTS implementation rules is, therefore, incomprehensible and has never been explained or justified in any credible way by either the GSEs or the Federal Housing Finance Agency (FHFA).
The nearly ten year delay in properly implementing this simple and straightforward congressional directive has harmed both consumers – who have been left hanging with no remedy — and the industry, which continues to suffer from unnaturally low production levels due to discrimination by the GSEs.
While a mandatory pilot program including chattel loans – combined with a specific commitment to transition to a full “going basis” securitization model within a short and finite timeframe — would potentially be a step forward, a chattel “pilot program” in itself would not fulfill the mandate of DTS. ##
Mark Weiss, JD
President & CEO
Manufactured Housing Association for Regulatory Reform (MHARR)
1331 Pennsylvania Ave. N.W., Suite 512
Washington, D.C. 20004