GSE’s Duty To Serve

The decision by the FHFA to exclude loans on manufactured homes on leased land from their proposed rules to implement the duty to serve underserved markets as outlined in HERA will be financially devastating to existing manufactured homeowners. If the GSE’s do not offer loan programs for MH homeowners, the financing available to potential home buyers will be severely limited, costly or non existent.

We recommend that community owners encourage their residents to write their congressional representatives and let them know that the GSE’s exclusion of MH loans in land lease communities will be devastating to the value of their homes, significantly limiting their ability to sell their home for a fair value, thereby causing severe financial loss if the resident needs to move. The resident should suggest that the FHFA should treat a manufactured homeowner the same as a stick built homeowner and not abandon the support of millions of MH homeowners living in MH communities.

MHI will be developing a sample letter in the next few days for distribution to community residents. The deadline for comments is July 22nd, so we must mobilize swiftly if we are to get resident comments to the FHFA by July 22nd.

Greg O’Berry
President and COO

10 thoughts on “GSE’s Duty To Serve”

  1. Great post, Greg. This measure effects homeowners in communities as well as the community owners. They need to be alerted to the impact of these decisions on the biggest investment of their lives. It's important that this angle was brought out into the light. Thanks for bringing it to our attention.

  2. Soheylakovach

    Dear FHFA officials,
    Congress in its wisdom gave us the Duty to Serve provisions for manufactured housing financing. I live in a manufactured home in Sunset Village, Glenview IL. I can tell you first hand how important it is to have this sort of workable home only financing. We live in a home that looks and lives like a conventional house, it is less than 5 years old. We are in a neighborhood that is being updated and improved by the owners of the community. To make some area housing comparisons: to the south are condos 45 years old that sell for 3 times the price of the home we live in. To the north are townhouses that are less than 10 years old, they sell for 5 to 10 times the price of the home we live in. They have home owner association fees, we have site lease fees. We pay less in taxes and fees than they do. But they have a financing advantage that we do not have! FHFA regulations that would make the playing field level with conventional financing for conventional housing would make it easier for millions to buy and sell their manufactured homes.

    Across the street from where my family lives are two story HUD Code homes. They are stylish, beautiful, safe and durable – it is required by federal law! Why should they – or we – have to suffer under financing terms that are unequal to conventional financing?

    Let's not forget that manufactured housing is made in the USA! We need to protect and grow this vital job segment.

    Sometimes officials say that manufactured housing loans 'don't perform as well' as conventional housing. In the aftermath of the sub-prime real estate meltdown, I'm not sure that is a valid argument any more. There are and will be households that don't make as much money as others, and they will be more vulnerable to economic issues. In other words, it isn't the house, it is a question of the income levels of those served. But if the government gave the same treatment to Manufactured Home owners that it has to those caught in the subprime mess, if MH owners had the same bail out programs and 'let's keep people in their homes' programs as those who get conventional financing, don't you think it would be easier and better for manufactured home owners too? Of course it would!

    Equal treatment under the law! That is what manufactured housing deserves! The federal government regulates this industry and form of construction. Manufactured Housing is designed to perform the same as conventional housing, but at a lower cost, by the terms of the federal law known as the HUD Code. If you give unfair/preferential treatment in financing to 'conventional housing,' you are penalizing some 20 million manufactured home owners and the millions more who could or would buy if the homes had absolutely equal footing in financing.

    You can't discriminate against races, religions, ethnic groups and a host of other groups. Why should the federal government tolerate any type of discrimination against a housing type it regulates?

    I'm asking you to level the playing field for manufactured home owners and residents like myself.

    I would observe that modern manufactured housing compared to conventional building – according to insurance and other studies I've seen – is as more energy efficient, as or more safe against a fire, lower maintenance costs, etc. Even if these home loans didn't perform as well, think about the billions of dollars the economy saves in the cost of buying and owning these homes!

    Finally, and a topic I don't here mentioned often. If people can't buy manufactured housing that is affordable, what do they turn to instead? Many will have no choice but to rent in subsidized housing! That is silly public policy! Why give billions to rental property owners, that often have older, less energy efficient houses, when much less money could go to supporting a greener, more energy efficient home that will create home owners and American jobs!

    Thank you.

    Soheyla Kovach

  3. Finewisconsinhome

    Good stuff.

    My suggested talking points for Congressional Representative, your US Senators and the FHFA

    You can use a format like what MHI or your state association has provided, or you can write your own message. MHI and Kovach are right, the key is volume! Don't put this off, we have 3 days to act, so write now and then tell your friends and co-workers to do the same.

    1.Congress has already required this Duty To Serve (DTS) Manufactured Housing. It is the law.
    2.The intent is to make financing easier for manufactured homes.
    3.There are about 20 million manufactured home owners. All of them are impacted in terms of resale ability when financing isn't readily available.
    4.A lack of financing hurts retailers, community operators, manufacturers and suppliers.
    5.All this means without proper financing, it costs jobs, with financing it creates or protects jobs.
    6.There are excuses that can be given 'not' to comply by the FHFA, but they are just that – excuses. Chattel lenders and private money lenders make these loans profitably and successfully, so can the government.
    7.Equal treatment of manufactured housing and conventional housing ought to be sound public policy, and it is de facto the law.
    8.The DTS and easier financing will save the government money in the long run, because subsidized rental housing can be avoided.
    9.It is worth saying again, Jobs and Economic benefit! But also greener building, energy savings, the government and media love hearing those words!

    Modular builders may not realize it, but this matters to them too. Like it or not, the HUD Code product influences Mods, and vice-verse. Everyone involved in factory built housing is impacted, suppliers, insurance companies, lenders, customers, everyone! Everyone should write and get their cousins and associates to do the same.

    gives you the links you need to write FHFA and Congress.

  4. Tim Connor, CSP

    Having served the Manufactured Housing industry for over 20 years as a speaker and trainer I can tell you that the Federal Government is not looking out for homowners, communities or Manufactured Housing manufacturers and that their decisions are grounded in arrogance, ignorance and a total lack of understanding of what Americans want and need and what the housing industry needs to thrive and create jobs, affordable living and a sense of emotional and economic freedom. Just one more example of the disconnect between the government and its citizens.

  5. Tim Connor, CSP

    Greg, great points, I've written FHFA, my 2 senators and Congressman. Thanks for your leadership on this key issue for the MH Industry! Tim Connor

  6. Ken Rishel just submitted an Industry Voices post at:

    In it, Ken is rallying the industry to TAKE ACTION NOW and write to FHFA, their Senators and Congressmen.

    I've made the point before that this is critical to the industry. We here at have taken the time to send those letters and emails.

    Now we need everyone who reads this to do the same.

    Ken is sending this to 9,000 subscribers on his mailing list. has repeatedly sent it to our list.

    Please take the time to send this on to your mailing list of employees, residents, customers, colleagues, etc.

    The DEADLINE FOR COMMENTS IS JULY 22, 2010. That's two days from now. There is no more time to waste. Get it done now!

  7. Greg McClanahan

    From rural America in SW Colorado, this is what I wrote my Congressman:

    Dear Congressman Salazar,

    I sadly must admit that this is the first time I’ve ever written a letter to my Congressman. I realize you need to hear from your constituents to know what is important to them and because this topic affects so many of us, it is my hope that this letter reaches you.

    Because much of Colorado is rural, manufactured homes make up a large part of our overall housing choice. A family who wants to keep their agricultural property separate from their home will select a manufactured home and subsequently offer a piece of the farm to their children as they grow up. This next generation will also choose to keep their home separate from the land because they do not want to subdivide the farm. I would venture to say that many of us who earn a modest income in our rural communities find that a manufactured home is our only way to enjoy homeownership. Young families, retirees and everyone in-between select manufactured homes in this state because it is their best housing option.

    With this as the backdrop, the decision by the FHFA to exclude loans on manufactured homes from their proposed rules to implement the duty to serve underserved markets as outlined in HERA will be financially devastating to existing and future manufactured homeowners. If the GSE’s do not offer loan programs for manufactured home homeowners, the financing available to potential home buyers will be severely limited, costly or non existent.

    In brief, I along with 18 million other Americans who enjoy homeownership today in a manufactured home, ask that you request that the FHFA amend this rule.

    In time of war, as our naval fleet traveled to the field of battle, they elected to travel at the rate of the slowest vessel because they were only strong as a fleet. Our nation remains the best place in the world to live because we have found ways to make sure a broad range of our citizens have a way to enjoy homeownership. Are we all able to be on the fastest and fanciest vessel? No, but we are all a valuable part of the strength of the overall fleet and the strength of this nation.

    I propose to you that this is a significant issue that threatens to impact the strength of this nation. Since 1989 manufactured homes make up 21 percent of the overall housing market. That just happens to be 2 of 10 ships that make us capable of maintaining our way of life – especially in rural America.

    I respectfully thank you for your time and implore you to become involved in this vital issue.

    Kindest regards,

    Greg McClanahan

    Thank you Greg for making us aware of this rule and the impact it will have on the MH community.

  8. Thayer Long- MHI

    Great work by Greg, Ken, and the entire MHI-National Communities Council.
    We expect that several hundred letters by residents, the individuals most affected by this initial decision, will be submitted as a result.

    Here is the text of the letter residents can use in case anyone has trouble locating it:

    Mr. Alfred M. Pollard, General Counsel
    Federal Housing Finance Agency
    1700 G Street, N.W. Fourth Floor
    Washington, DC 20552
    Subject Line: RIN 2590-AA27

    Re: Duty to Serve Manufactured Housing Industry RIN 2590-AA27

    Dear Mr. Pollard:

    I am one of the roughly 10.8 million people who own and live in a manufactured home and reside in a manufactured home land-lease community. Please consider this letter as a response to the Enterprise Duty to Serve Underserved Markets Notice of Proposed Rule Making and Request for Comments (RIN 2590-AA27) released June 7, 2010 by the FHFA.

    In its proposed rule, FHFA indicates that it will not consider supporting manufactured home personal property loans. I am adversely affected by this proposal. Manufactured housing is a key segment of the housing market. Without manufactured housing, millions of families would not even have access to the American goal –and dream – of owning a single-family home. FHFA’s initial decision to exclude personal property lending considerations from the GSEs’ duty to serve denies millions of Americans the opportunity for homeownership.

    Access to a personal property loan is already very difficult to obtain, so participation by the GSEs in this market is critical not only to ensure opportunities for homeownership, but also to provide financing for buyers when existing homeowners need to sell their homes. Market values for resale manufactured homes are severely depressed today because of the lack of available financing, and many families like mine have been hurt as a result. In many cases, families that needed to move for family, health, job, or economic reasons have been unable to sell their homes at any price due to the lack of available financing. Denying us financing opportunities is unfair and can severely reduce the value of my home. It can destroy equity many have worked so hard to build.

    As a taxpayer, I appreciate the concerns raised by FHFA to ensure the GSEs remain economically viable institutions and that adequate consumer protections are in place. But FHFA and the GSEs also have an obligation to serve manufactured housing and the 10.8 million Americans that currently reside in manufactured home land-lease communities. I believe the manufactured housing industry stands ready to address personal property lending issues identified by FHFA in the proposed rule in a substantive and productive manner that results in economically viable programs that also serve these woefully underserved markets.

    The proposal by FHFA fails to serve the families who enjoy the benefits and the ability to live in manufactured homes and manufactured home communities. As a manufactured homeowner, I urge FHFA to amend its proposed rule to also consider manufactured home personal property loans as part of the GSEs duty to serve.

    Thank you for your consideration of these comments.


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