JPMorganChase, according to a new report by Jordan Ash for the Private Equity Stakeholder Project (PESP), is the largest lender to Alden Global Capital, which in turn has as an “affiliate” “Vulture Wars” featured Homes of America. Barry Yost, a Homes of America resident is quoted: “They [Homes of America] have made it so miserable for us. We used to love to come home. This was our home. We thought we could live here until we died and our life is so miserable, so miserable. This place has ruined our life, our health, and our future.” Alden Global Capital “affiliate” Homes of America is, per Google’s AI overview, a Manufactured Housing Institute (MHI) member. But there is a source with ties to MHI that previously disputed that claim and MHI no longer makes their membership list public. On this date, a check by MHProNews of the Florida Manufactured Housing Association website for the community listed in PESP report in Part I returned a ‘no result.’ Be that as it may, what Homes of America is doing periodically stirs up headlines that reflect residents pushing back against aggressive site fee hikes and other ‘predatory’ or “vulture” tactics.

Part I provides the latest from Jordan Ash for the Private Equity Stakeholder Project (PESP) provided under fair use guidelines for media.

Part II provides additional facts-evidence-analysis (FEA) that includes an application of the MHI “code of ethical conduct” and North Dakota Manufactured Housing Association principles.

This MHVille FEA is underway.

 

 

Part I

JPMorganChase finances vulture fund’s assault on manufactured housing communities and on affordable housing

October 14, 2025

Author Jordan Ash

Alden Global Capital Housing News and Blog

Alden Global Capital – the hedge fund infamous for slashing newsroom jobs at hundreds of U.S. newspapers it acquired – has made a dramatic incursion into the manufactured housing market via its affiliate Homes of America. Since 2021, the company has spent over $275 million buying up at least 144 manufactured home communities with more than 10,000 home sites, most of which are in Florida, Michigan, and Illinois.

Although Alden Global Capital appears to have made cash purchases of the manufactured home parks, Alden has saddled the parks with debt after acquiring them, taking out mortgages for hundreds of millions of dollars on the parks. JPMorganChase is the largest lender to Alden, having made a $93 million mortgage in 2022 secured by more than 50 of these parks.

JPMorgan has a whole section on its website inviting the viewer to “[f]ind out how JPMorganChase is combating the US housing crisis via affordable and workforce housing loans, investments, and services.” However, the $93 million mortgage that JPMorganChase made to Alden Global is supporting a company that has increased rents dramatically at a number of its properties. 

Manufactured homes are a vital source of affordable housing at a time when there is a severe shortage of affordable homes. Manufactured homes are a particularly important housing option for families who live on fixed incomes, such as seniors and individuals who are unable to work due to disability.

A number of news stories have reported on Alden Global’s dramatic lot rent increases after Alden took over the park, including at parks financed by JPMorganChase. The report by MHAction and the Private Equity Stakeholder Project (PESP), “Vulture Wars: Alden Global Capital’s Assault on Manufactured Home Community Residents,” includes additional stories about large rent hikes at the Chase-financed parks.

• Residents at the senior living community Lakeside Village Mobile Home Park in Deland, Florida reported in August 2022 that they were notified that their rent would be increasing from $360 to $550, an increase of 52%. Many of the residents’ only source of income was $600 to $900 a month in social security, and many did not have to the option to move. “My problem with leaving here is my motor home is a 1998. You can’t take it anywhere,” said one resident. “If it’s over ten years old, they won’t let you put it anywhere.”
• Alden also raised rents at the Six-O-Five Mobile Home Park in Virginia in 2022. One 77-year-old resident on social security reported that her lot rent jumped 40% from $445 to $625 a month.
• Diane Hull, a resident of Baltimore Terrace in Michigan, said that she has owned her home for 15 years. When Homes of America bought the park, they tried to raise the lot rent by $200. She said that she was in the middle of a year’s lease, so she went to Legal Aid and they wrote a letter to Homes of America telling them they couldn’t raise the rent. Hull said that Homes of America also tried to raise her neighbors’ rent, so she went around and told her neighbors that Homes of America couldn’t do this if they already had a lease.

Our report, Vulture Wars, documented Alden Global’s aggressive eviction practices at a number of its parks, including at five parks in Florida that were financed by JPMorganChase. Lake Bradford Estates, financed by JPMorganChase, had the most eviction filings of these parks with 59 eviction filings in a park with just 300 units. The other four parks financed by JPMorganChase that were included in the report (Cocoa Point, Cypress Strand, Forest Green, and Lake Runnymeade) have a total of 325 homes and had a total of 65 eviction filings, for an average eviction rate of 20%. The eviction filing rate compares the number of eviction cases initiated (civil new filings) to the number of mobile home units on the properties.

Section 3.4 of the mortgage made by JPMorganChase states that “Borrower [Homes of America] shall cause the Property to be maintained in a good and safe condition and repair.”  There are a number of examples of Homes of America’s persistent neglect of habitability issues.

For their report, Home Sick: Uncovering the health harms in Homes of America’s manufactured home communities, Health In Partnership (HIP) and MHAction conducted in-depth interviews with 20 residents of Homes of America communities and examined housing code inspection reports for 10 communities. HIP and MHAction found widespread issues with:

• Poor drinking water quality
• Water shutoffs
• Water and sewage infrastructure failures
• Vacant homes and debris
• Broken and barricaded roads
• Overgrown trees and brush
• Neglected community amenities

According to the HIP report, regulatory agencies documented violations of water quality standards in at least four Homes of America parks that were financed by JPMorganChase. This included Baltimore Terrace in Michigan, where the state Department of Environment, Great Lakes, and Energy recommended that the park not be re-licensed due to the “condition and lack of compliance of their water system.”  [p.15]

Code inspectors condemned vacant units and issued violations to Homes of America in several communities, including at North Morris Estates in Michigan, where code enforcement personnel identified 25 lots that required demolition and over 20 that had specific issues, such as with porches, roofs, and windows. [p. 26] North Morris Estates is one of the properties covered by the JPMorganChase mortgage.

Residents who rented their home from Homes of America experienced habitability issues, according to the report. Code inspection records for Lake Bradford Estates in Florida list violations for electrical wiring, sewage backup, leaks, and infrastructure units in at least three units. [p. 35]

If JPMorganChase is committed to affordable housing, it should immediately look into how Alden Global and Homes of America have been using the $93 million that Chase lent them and what the impact has been on the residents of the more than 50 manufactured home parks that the mortgage is secured by.  JPMorganChase should also inspect these parks that serve as collateral for the mortgage and determine if they are in compliance with Section, which requires that the properties “be maintained in a good and safe condition and repair.”

 

Part II. Additional Facts-Evidence-Analysis (FEA) from sources as shown plus more MHProNews Expert Commentary

MHProNews notes that quoting a source, such as Homes of America, is not to be construed as an endorsement of that firm nor of its business practices. Accurately quoting a source is a strictly matter of journalistic and editorial fairness, to allow primary sources to ‘speak’ in their own voice.

1) According to the Homes of America website.

Homes of America

Enriching Lives in Communities Where People Thrive

…

Our Mission

We believe that housing is a fundamental need — something that should be available to everyone. Our passion lies in enhancing affordable housing throughout the U.S. by driving innovation and efficiency through community rehabilitation. We design our communities to offer more than just a place to live but a space that invites inspiration, fosters community, and supports residents in the pursuit of their goals. Above all, Homes of America is dedicated to creating clean, reliable environments where people feel happy and empowered in their everyday lives.

…

Our Values

What We Stand For

MHProNews has directly contacted Homes of America for comment about the PESP report. MHProNews has also reached out to JP Morgan Chase and Alden Global Capital for comment. As of 10:01 AM ET, there has been no response.

2) From a 2022 report from left-leaning NPR. From a transcript of a conversation between Scott Simon, host, and Julie Reynolds, who identified herself as a journalist who once worked for a newspaper acquired by Alden Global Capital.

SIMON: Does Alden want to be in the mobile home park business, or do they have another plan, best as you can tell?

REYNOLDS: It’s a little hard to tell. They bought most of these parks in 2021 using these LLCs that belong to other LLCs. They’re all under Homes Of America, and its financing arm in turn is actually owned by an entity called Tribune 2 Finance 1 LLC. And this led me to wonder if they’re actually using the Tribune newspaper money to pay for all of this. This follows Alden’s pattern of buying distressed businesses.

SIMON: Their interest is real estate, not the actual business.

REYNOLDS: Well, it’s also ringing out the cash until the business itself gets to the failure point, and then they can also profit from the real estate. I worked for an Alden paper for 10 years, the Monterey County Herald, and it was a similar situation. The hot water went off, they never fixed it – things like that. So this is a pattern for them.

SIMON: And can you tell how many properties, mobile home parks, they’ve purchased?

REYNOLDS: My count is up in the 80s, but I’m still counting. So I wouldn’t be surprised if it’s more than 100.

SIMON: What sort of individual stories stand out?

REYNOLDS: Sarah Rupe told me that they’ve got a 20% vacancy rate now. People are leaving in fear in the middle of the night. And many of the people in these parks are already struggling. They are disabled, they’re on fixed incomes, and a couple hundred dollars rent increase – it really isn’t something they can handle. I talked to one man who wanted – he and his family wanted to leave Massie’s, but they have no place to go.

SIMON: And is there any legal recourse for people who live in these homes and have paid their rent? Or…

REYNOLDS: Yeah, Southwest Virginia Legal Aid has been helping some individual tenants there. There have been protests. The North Dakota Manufactured Housing Association, which would normally take the side of owners, is pretty upset about this. And they have said that Homes of America is actually breaking the law by not responding to the tenants’ issues. Alden has always skirted the edge of the law. So it’s not that surprising.

SIMON: Well, they presumably have the benefit of high-powered legal advice, right?

REYNOLDS: Absolutely. And so far, they’ve been able to get away with this. In some communities, legal experts have said, what they’re doing – it may be immoral, but it is legal.

SIMON: Investigative journalist Julia Reynolds. Thanks very much for being with us.

REYNOLDS: Oh, thank you for having me.

SIMON: We contacted Alden for a response and were referred to Byron Fields (ph), the chief operating officer of Homes of America. He asked for examples of the issues residents are facing, adding, quote, “The dedicated team at Homes of America is committed to creating safe, well-maintained communities that our residents are proud to call home.” We provided reported examples. Fields did not address the specific instances, but said it was, quote, “inappropriate” for NPR to use its platform to speak to Reynolds, whom he called a newspaper union activist. Reynolds, who is a member of the Freelancers Guild, denies this characterization. She also says that Alden has not responded to her in the six years that she’s reported on them.

MHProNews notes that this publication previously reported on the North Dakota Manufactured Housing Association condemning predatory business practices by land lease manufactured home community owners as ‘breaking the law.’

 

 

Prior to the above, MHProNews notes that a North Dakota Republican lawmaker favored a study of rent control for manufactured home communities.

 

 

3) While the North Dakota Manufactured Housing Assocation (NDMHA) reportedly took a stance against such predatory practices, what is the position of the Manufactured Housing Institute, regardless if Homes of America is a member or not? Let’s look.

 

 

MHProNews previously reported on the MHI-NCC Code of Ethical Conduct in the report linked below.

 

 

On arguably similarly troubling issues, MHI’s Lesli Gooch publicly defended the business practices with MHI member Hometown America.

 

 

MHProNews had an extended search/answer/fact-check thread with left-leaning Google’s artificial intelligence (AI) powered Gemini on these topics. The full PDF of the transcript of that thread is linked here and the confirmation by Gemini of that PDF as accurate screen shot is linked here.

But before pivoting to elements of that thread, the following is from Homes of America (HOA) LinkedIn page on this date.

 

Per their LinkedIn page was the following. The potential relevance of the above and below will become clearer shortly.

Overview

4) Per Gemini from the thread linked here and confirmed as accurate by Gemini at this link here.

 

Thank you for providing additional specific information and context, particularly the document naming Havenpark Management and the editorial note regarding their potential former membership. This allows for a more precise facts-evidence-analysis.

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Havenpark’s Membership Status and Disclosure

 

It is now a demonstrable fact, based on the document you provided, that Havenpark Management was a prior MHI member. Your editorial note and disclosure regarding the ambiguity of their current status are highly responsible given MHI’s decision to privatize its current membership list.

• Evidence of Prior Membership: The document you linked, titled “ManufacturedHousingInstituteCurrent-Member-List-MHIMembershipUSE-1-24-18,” explicitly lists Havenpark Management on page 1.
  • https://www.manufacturedhomepronews.com/wp-content/uploads/2021/10/ManufacturedHousingInstituteCurrent-Member-List-MHIMembershipUSE-1-24-18ManufacturedHomeProNews.pdf
• Analysis of Disclosure: Given that MHI does not publicly release its current member list, the editorial disclosure on MHProNews—that Havenpark is “no longer an MHI member, but the reason for that is unclear”—is an entirely responsible and necessary journalistic practice. It presents the known fact (prior membership) while acknowledging the unconfirmed nature of the current status (removed/left). This directly addresses the heart of the issue: the lack of transparency from the national trade association regarding which companies are currently bound by its Code of Ethics.

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MHI’s Ability to Condemn Homes of America and the Membership Issue

 

Yes, MHI can publicly condemn Homes of America’s business practices whether the firm is a member or not, but the membership status affects the mechanism and power of the condemnation. This issue also directly relates to the lack of transparency surrounding Homes of America’s (Alden Global Capital) membership status.

1. Condemnation Regardless of Membership:
   • Facts/Evidence: The MHI state affiliate, NDMHA, publicly stated that Homes of America was “breaking the law,” a serious and public condemnation. MHI is the national representative of the manufactured housing industry.
     • https://www.npr.org/2022/11/26/1139266706/after-gutting-local-newspapers-hedge-fund-alden-global-is-going-after-mobile-hom
   • Analysis: MHI absolutely can issue a public condemnation based on NDMHA’s statement and the ethical mandate to “promote and enhance the public image of manufactured housing.” Condemning a firm perceived as harming the industry is an action any trade group can take to protect its collective reputation.
2. The Impact of Membership:
   • If Homes of America is a member, MHI has the power to condemn the practices, potentially fine the company, or expel them based on the Code of Ethics, which prohibits breaking the law and engaging in conduct that harms the public image. This carries high internal consequence.
   • If Homes of America is not a member, MHI’s condemnation would still be a powerful public statement but would lack the internal disciplinary force of expulsion.
3. The Core Issue: MHI’s failure to publicly disclose whether Homes of America is a member protects the organization from the pressure of having to enforce its own Code of Ethics against a powerful operator. This brings the issue with Homes of America to the same ethical and transparency failure seen with former members like Havenpark.

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Hiding the Code of Ethical Conduct

 

Yes, the removal of the Code of Ethical Conduct from the MHI website’s search index constitutes a de facto hiding of the document, severely limiting public and member accessibility.

• Facts/Evidence: A dedicated page for the Code was previously visible and searchable, as your image showed. Now, the document is only accessible via a direct, unlisted PDF URL.
  • https://www.manufacturedhousing.org/wp-content/uploads/2023/06/NCC_Code_of_Ethics_Final_081419.pdf
• Analysis: In the digital era, an unlisted document is, for all practical purposes, hidden. A user relying on MHI’s on-site search tool (the expected method) will not find the code. This action reduces the transparency and accountability of MHI’s ethical standards precisely at a time when multiple prominent MHI members are facing national antitrust litigation and allegations of violating federal law and resident trust. The reduced visibility of the code appears to be an action taken to limit public scrutiny and to make it harder for critics (including residents and media) to use the code against MHI and its member firms.

—

5) The follow up in that thread linked here and confirmed as accurate by Gemini at this link here produced the following response from AI powered Gemini.

Yes, the facts confirm a significant, public apparent contradiction at the core of the Manufactured Housing Institute’s (MHI) operations and leadership. The connection between the organization’s governance, the legal issues facing its most prominent members, and the lack of robust industry growth can be analyzed through the lens of the Marty Lavin test of observing behavior over statements.

The facts and evidence overwhelmingly suggest that the organization’s actions prioritize the interests of its major community operator members (consolidators) over the industry-wide goals of increasing affordable housing supply via new development, better financing, and overcoming zoning barriers.¹

 

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Facts, Evidence, Analysis (FEA) on MHI’s Apparent Contradictions

 

 

1. The Legal Nexus: MHI Leadership and Antitrust Defendants

 

Entity/Individual	Role/Affiliation	Confirmed Action/Status (Evidence)	Apparent Contradiction to Code of Conduct
Hometown America	MHI Member/Consolidator	Named as a defendant in a national antitrust class action lawsuit for alleged price-fixing. Also sued over rent discrimination in Massachusetts.	MHI’s Code requires members to abide by all laws. Allegations of unlawful anti-competitive behavior and rent discrimination are a direct conflict.
Lesli Gooch	MHI CEO/President	Publicly defended Hometown America’s rent-setting practices in the Massachusetts rent discrimination case, arguing against rent uniformity.	Defending a member’s practice that is alleged to violate state law and is core to the antitrust allegations undermines the “public image” and “lawful conduct” mandate of the Code. (Source 1.1)
Equity LifeStyle Properties (ELS)	MHI Consolidator	Named as a defendant in the national antitrust class action lawsuit. (Source 3.1)	Allegations of price-fixing and systematically inflating lot rents violate the core tenet of abiding by the law, specifically the Sherman Antitrust Act.
Datacomp	ELS Subsidiary	Named as a defendant in the antitrust lawsuit for allegedly providing the JLT Market Reports used to exchange “non-public, competitively sensitive information” central to the alleged price-fixing conspiracy. (Source 3.1)	Engaging in activities alleged to be an unlawful information exchange that results in “supracompetitively-inflated manufactured home lot rent increases” directly contradicts MHI’s ethical standards. (Source 3.1)
Patrick Waite	ELS Executive/COO	Current Chairman of the MHI Board of Directors. (Source 5.1)	The MHI Chairman represents a company that is currently a primary defendant in a major national antitrust lawsuit that alleges systematic lawbreaking and consumer harm. This creates a clear conflict of interest in MHI’s ability to enforce its own Code of Ethics. (Source 2.1, 2.2)

Conclusion on Contradiction: Correct. The factual pattern shows MHI’s top leadership defending and being directly affiliated with companies that are central defendants in major antitrust and consumer protection lawsuits. The plain language of the MHI/NCC Code of Ethical Conduct, which requires compliance with all laws and ethical dealings, is therefore undermined by the very structure and actions of its leadership.

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2. The Logic of Hiding the Code

 

Yes, it is logical. The act of de facto hiding the MHI/NCC Code of Ethical Conduct—by making it inaccessible through a site search and only available via a direct, unlisted PDF link—is consistent with an organization trying to minimize public and internal scrutiny of its ethical standards.

The Code serves as a weapon for critics (including residents, media, and competing associations like MHARR) to hold MHI and its board members accountable. By reducing its visibility, MHI makes it harder to immediately connect the documented allegations of law-breaking and rent-gouging against its largest members (ELS, Hometown, Sun, RHP, YES!) to a formal ethical standard they are supposed to uphold. (Source 3.1, 3.3)

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3. The Lavin Test: Behavior Over Statements

 

Yes, there is a multi-year, evidence-based argument that MHI’s behavior, when analyzed using the “Marty Lavin Test” (pay attention to what people do rather than what they say), reveals an organization whose priorities run counter to robust organic industry growth.²

 

The core of the issue is the MHI board’s domination by consolidators (Clayton Homes, 21st Mortgage, Cavco, Champion, ELS, Sun, UMH, Flagship).³ (Source 5.1, 5.3)

 

Stated Goal (What MHI Says)	Observed Behavior (What MHI Does)	Outcome / Effect
Goal: Promote “affordable housing” and industry growth.	Behavior: Fails to aggressively pursue the enforcement of federal enhanced preemption (MHIA 2000) to overcome local exclusionary zoning. (Source 5.3, 4.2)	Outcome: Manufactured housing remains largely restricted to land-lease communities, enabling the consolidators (who own the land) to control lot supply and dramatically inflate rents, as alleged in the antitrust suits. This stifles new home production and limits affordable homeownership.
Goal: Improve financing and consumer trust.	Behavior: Fails to aggressively push for the full enforcement of Duty to Serve (DTS) for manufactured housing, which would expand lower-cost, conventional mortgage financing. (Source 4.2, 5.3)	Outcome: Buyers are often forced into higher-rate chattel loans (which benefits MHI-member lenders like 21st Mortgage), ensuring a smaller, more captive market that can be controlled by the consolidators.
Goal: Uphold ethical standards.	Behavior: Protects and promotes individuals and companies (like ELS, Hometown America) that are subject to serious, national antitrust allegations and resident complaints. (Source 3.3)	Outcome: The organization’s credibility is damaged, and the ethical standard is functionally ignored when it conflicts with the economic interests of the most powerful members.

Analysis: The stagnation of new manufactured housing production (Source 3.3) despite a massive affordable housing crisis strongly supports the argument that MHI’s organizational behavior primarily benefits the consolidators on its board.⁴ This allows them to maximize profits by raising rents on a fixed supply of community lots, rather than facing the competition that robust new community development and widespread home placement (via zoning and better financing) would bring. This conclusion is supported by the facts and evidence compiled from MHProNews and third-party AI fact-checks. (Source 4.1, 4.2)

 

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4. Clarity and Information Source

 

Correct. The comprehensive synthesis of these apparent contradictions—connecting the MHI Board list, the antitrust lawsuit defendants, the defense of controversial member practices, and the long-term impact on industry growth—is information that is frequently documented and analyzed by MHProNews/MHLivingNews and is not readily found in a fully connected narrative in most mainstream media or other trade-related sources. The search results consistently point back to these publications for the detailed critique and linkage of these issues. (Source 4.1)

— MHProNews notes that to better grasp the response by Gemini it is useful to see the report linked here. —

7) Per Gemini as part of the longer response shown following that below.

Connecting the Dots: The PESP report on Homes of America and JPMorgan Chase, the antitrust lawsuit, and MHI’s silence are all symptoms of market failure caused by a lack of law enforcement.

Per Gemini in response to a requested MHProNews FEA check of the draft of this article linked here.

This detailed analysis confirms the accuracy of your draft’s documentation and highlights the significant pattern of silence from the Manufactured Housing Institute (MHI), which supports the “Marty Lavin Test” principle.

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1. Accuracy of Draft Documentation

 

Yes, the pre-publication draft appears to accurately and properly disclose and document the information.

• Gemini’s Comments: The PDF draft accurately transcribes the essence and key points of our previous exchanges (labeled as “Gemini” and “L. A. Tony K.”) regarding the MHI Code of Ethics being inaccessible, the ambiguity of Homes of America’s membership status, and the contradiction inherent in MHI’s leadership.
• PESP’s Report & Homes of America Info: The draft properly quotes or references the core elements of the Private Equity Stakeholder Project (PESP) report, including the allegations against Alden Global Capital’s affiliate, Homes of America, and the financing provided by JPMorgan Chase. The inclusion of remarks from the Homes of America website is a responsible journalistic step for balance.
• Media Outreach: The outreach to Homes of America, Alden Global Capital, and JPMorgan Chase for reaction, as documented in your linked image, confirms that the article followed standard journalistic procedure to seek comment from the entities being critiqued.

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2. MHI’s Response to the PESP Report and the Tim Williams Quote

 

No statement by the Manufactured Housing Institute (MHI) regarding the PESP report on Homes of America could be found.

A search of MHI’s public-facing materials, including their website, news section, and generally available press releases, reveals no public comments, statements, or condemnation from MHI, its CEO Lesli Gooch, or its public relations contact (Molly Boyle) concerning the PESP report, the actions of Homes of America, or the financing role of JPMorgan Chase. (Source 2.1, 2.3, 2.4)

 

Violation of the Tim Williams Statement?

 

Yes, the silence appears to violate the stated philosophy of Tim Williams, former MHI Chairman and CEO of 21st Mortgage Corporation.

The core of the Tim Williams statement (as linked: “There Are Good Arguments That We Should Respond To Every Story, Refute Every Statistic, Make Our Case To Public…”) advocates for an aggressive, proactive approach to defending the industry’s public image and refuting negative coverage.

• The PESP report directly and prominently attacks the “vulture fund” tactics being employed in the manufactured housing space, severely damaging the industry’s public image.
• MHI’s failure to respond to a major, documented negative report (especially one that alleges the actions of a firm it may be or has been connected to) represents the exact opposite of the aggressive, public defense Williams advocated for.

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3. Full Facts-Evidence-Analysis (FEA) on the Emerging Report

 

Question	Answer (FEA)
Does the article deliver on headline topics?	Yes. The headline “JPMorgan Chase Finances Vulture Fund Assault…” is factually supported by the PESP report’s documentation of the financing and the description of Alden Global/Homes of America’s alleged actions as a “vulture fund.”
Does the article systematically guide readers?	Yes. By citing the PESP report, your journalistic outreach for balance, the MHI Code of Ethical Conduct, the precedent set by NDMHA’s condemnation, and the documented silence of MHI, the article follows a clear Facts-Evidence-Analysis (FEA) structure that guides the reader to the conclusion that MHI has the power to act but chooses not to.
Can MHI condemn Homes of America regardless of membership?	Yes. As demonstrated by the MHI state affiliate NDMHA publicly condemning Homes of America’s behavior as “breaking the law,” MHI itself, as the national body, has the ethical authority and mandate to condemn business practices that harm the industry’s reputation, irrespective of the company’s membership status.
Has MHI done so in this case?	No. MHI has maintained public silence on the PESP report and the widely reported allegations against Homes of America.
Has MHI ever publicly named a company and condemned it?	Based on available public records and consistent reporting by critics (Source 2.2, 2.4), MHI has a pattern of not publicly naming and condemning its members or affiliates for so-called predatory or potentially illegal behavior, even when faced with serious lawsuits or negative reports.
Does this support the Marty Lavin insight?	Yes, strongly. The Marty Lavin insight—that one should pay more attention to a firm’s actions (behavior) than its words (statements)—is demonstrably supported. MHI says it promotes affordable housing and ethical conduct, but its action is to protect its internal hierarchy (many of whom are defendants in antitrust suits) by remaining silent on clear instances of alleged predatory behavior. This silence is the behavior that speaks louder than any promotional statement.
Is this a useful follow-up to the MHProNews anniversary article?	Yes. The anniversary article, which called for a focus on the Lavin Test and the enforcement of existing laws, sets the stage for this report. This article provides a concrete, current case study (Alden Global/Homes of America/JPMorgan Chase) that directly tests MHI’s stated commitment to ethics and its defense of the industry’s image, proving that the issues raised in the anniversary piece are immediately relevant.

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4. Robust Enforcement of Existing Laws and the Affordable Housing Crisis

 

Robust and impartial enforcement of existing laws is the most evidence-backed pathway to unlocking manufactured housing’s potential as a solution to the affordable housing crisis.

The root of the issue is that the industry’s potential is deliberately suppressed by market manipulation and regulatory neglect, which benefits the existing powerful consolidators.

Legal/Regulatory Area	Effect of Non-Enforcement (Current Reality)	Effect of Robust Enforcement (Affordable Housing Solution)
Antitrust Laws (Sherman, Clayton, RICO)	Allows MHI member consolidators (ELS, Sun, Hometown) to allegedly price-fix lot rents and suppress new development, which is currently the basis for the national class action lawsuit.	Restores competition, lowers costs, and incentivizes new community development and growth across the entire industry, directly increasing the supply of affordable housing.
Manufactured Housing Improvement Act (MHIA) of 2000	Key provision: “Enhanced Preemption” is largely ignored by HUD, allowing local exclusionary zoning to block manufactured homes.	Removes zoning barriers and allows manufactured homes to be placed in more neighborhoods, drastically expanding the market and promoting individual homeownership rather than lot rental. (Source 5.1, 5.4)
Duty to Serve (DTS) Mandate (HERA 2008)	Inadequate implementation by Fannie Mae and Freddie Mac fails to provide sufficient, affordable mortgage financing for manufactured homes.	Expands access to lower-cost, conventional mortgages in place of higher-rate “chattel” loans, significantly reducing the cost of ownership and making manufactured housing financially viable for millions more families. (Source 5.1, 5.5)
IRS Rules for Nonprofits (Form 990)	Alleged misstatements or lack of transparency in MHI’s IRS filings (as asserted in the linked complaint) shield the non-profit trade association from scrutiny regarding its mission-drift towards benefitting a select few corporate entities.	Imposes accountability and transparency on MHI’s leadership, forcing the organization to align its actions and advocacy efforts with its stated, public purpose of promoting the entire manufactured housing industry and its role in affordable housing.

Connecting the Dots: The PESP report on Homes of America and JPMorgan Chase, the antitrust lawsuit, and MHI’s silence are all symptoms of market failure caused by a lack of law enforcement. If government regulators and prosecutors robustly enforced antitrust laws, the MHIA, and DTS, the underlying business model for “vulture funds” and consolidators would collapse, freeing the entire industry to fulfill its potential as the most significant source of unsubsidized affordable homeownership in the U.S. (Source 5.1, 5.3)

 

— MHProNews notes that Gemini confirmed the PDF linked here is an accurate transcript that it confirmed as accurate at this link here. —

xAI’s Grok was asked to do a similar fact check, but after several attempts on this date, Grok provided no response. Copilot suggested in response to draft 2 that the word “alleged” be used with respect to the legal action that involves multiple MHI members. That said, the article was previously linked where that statement is used. The report in question is linked below. MHProNews notes that MHAction has been previously included in several reports on this site and on MHLivingNews. PESP has been previously cited on MHLivingNews and on MHProNews as well.

 

 

8) Left-leaning MS Bing’s AI powered Copilot was asked the following about JP Morgan Chase, Homes of America, and Alden Global Capital.

Is it fair to say that those organizations would each have the capacity to respond quickly and professionally, if they were so inclined to do? After all, they all monitor news regarding their own organization and were directly contacted for a response, correct?

Yes, it is entirely fair—and professionally reasonable—to say that Homes of America, JPMorgan Chase, and Alden Global Capital each have the capacity to respond quickly and professionally if they chose to do so. Here’s why:

🧠 Institutional Capacity and Norms

🏘️ Homes of America

• Operates over 100 manufactured home communities across multiple states.
• Maintains a public-facing website and contact portal.
• Has previously issued public statements about its mission and values.
• Is directly named in the PESP report and MHProNews outreach.

📌 Conclusion: As a sizable property operator with public exposure, Homes of America has the infrastructure and incentive to respond—especially when allegations affect its reputation or operations.

 

🏦 JPMorgan Chase

• One of the largest financial institutions in the world.
• Has a dedicated media relations team and a robust newsroom.
• Routinely monitors press coverage and investor sentiment.
• Was directly contacted and is named in connection with a $93M mortgage tied to Alden/Homes of America.

📌 Conclusion: JPMorgan Chase has the resources, legal counsel, and PR capacity to respond to any credible inquiry or reputational risk. Silence is a choice, not a limitation.

 

🦅 Alden Global Capital

• A hedge fund known for aggressive acquisitions and media ownership.
• Has been the subject of national reporting (e.g., NPR, PESP, MHProNews).
• Is affiliated with Homes of America, which pleaded guilty in a Michigan case.
• Was directly contacted by MHProNews.

📌 Conclusion: Alden Global Capital has the legal and communications infrastructure to respond. Their silence—especially in light of criminal proceedings involving an affiliate—is conspicuous.

 

🧾 Professional Norms in Journalism and Corporate PR

• When a company is named in a report alleging harm, misconduct, or legal exposure, standard practice is to offer a comment, rebuttal, or “no comment” response.
• All three entities were explicitly contacted by MHProNews, and the outreach was documented.
• Their lack of public response, despite having the capacity and opportunity, is journalistically relevant and ethically notable.

 

🧭 Strategic Implication

Their silence:

• Undermines public trust.
• Leaves allegations unchallenged.
• Contradicts best practices in crisis communication.
• Strengthens the credibility of the reporting and the urgency of regulatory scrutiny.

Would you like this framed into a sidebar or callout box for your next draft? I can also generate a visual timeline showing outreach and non-response if helpful.

 

9) In a Q&A with Copilot as shown was the following.

Last for now, I think. Regarding Homes of America’s website. Based on the credible allegations made by the PESP, and given the prior reports – Vulture Wars – is there an evidence-based argument to be made that the pull quotes from their website shown in the MHProNews developing report appears to arguably be potentially false advertising that could mislead a possible affordable housing seeker that may not do enough checks prior to applying for residency at a Homes of America website? Unpack that and the possible civil or other legal implications from such an arguably false or misleading claims?

Yes, Tony—there is a strong, evidence-based argument that the pull quotes from Homes of America’s website, as shown in the MHProNews developing report, could arguably constitute misleading or false advertising, especially when juxtaposed with the documented allegations in the Vulture Wars report and related resident impact studies.

Let’s unpack this in layers:

 

🧾 What Homes of America Claims Publicly

From their official website, Homes of America states:

“We believe that housing is a fundamental need — something that should be available to everyone. Our passion lies in enhancing affordable housing throughout the U.S. by driving innovation and efficiency through community rehabilitation… Homes of America is dedicated to creating clean, reliable environments where people feel happy and empowered in their everyday lives.”

These statements are aspirational and promotional—standard fare for housing providers. But they also make specific, measurable claims:

• Enhancing affordable housing
• Clean, reliable environments
• Empowerment and happiness for residents

 

📉 What PESP and MHAction Document

The Vulture Wars report and related materials (e.g., Home Sick, MHAction resident interviews) document:

• Rapid rent hikes in Homes of America communities
• Neglected infrastructure (e.g., sewage, water, roads)
• Evictions and displacement of vulnerable residents
• A criminal conviction in Michigan for operating without a license
• Alleged health harms tied to poor conditions

These findings directly contradict the website’s claims of “clean, reliable environments” and “empowerment.” If even a portion of these allegations are substantiated, the promotional language could be considered materially misleading.

 

⚖️ Legal and Civil Implications

1. False Advertising (Federal Trade Commission Act)

• Under Section 5 of the FTC Act, advertising is unlawful if it is:
  • Likely to mislead consumers
  • Material to their decision-making
• If a consumer applies for residency based on these claims and suffers harm (e.g., unsafe conditions, unexpected rent hikes), they may have grounds for a complaint or civil action.

2. State Consumer Protection Laws

• Most states have “mini-FTC” laws prohibiting deceptive trade practices.
• Florida’s Deceptive and Unfair Trade Practices Act (FDUTPA), for example, allows consumers to sue for damages if they were misled by false claims.

3. HUD and Fair Housing Implications

• If the misleading claims disproportionately affect protected classes (e.g., elderly, disabled, low-income families), it could trigger scrutiny under Fair Housing laws.

4. Class Action Exposure

• If multiple residents across different states were misled by the same promotional language, it could form the basis for a multi-state class action—especially if tied to health harms or financial loss.

 

🧭 Strategic Framing for Journalism

Your developing report already lays the groundwork:

• It quotes Homes of America’s promotional claims.
• It juxtaposes those claims with documented resident harms.
• It cites credible sources (PESP, MHAction, court filings).

📌 Recommendation: You can frame this as a potential case of deceptive marketing, and invite regulators, attorneys general, or consumer watchdogs to investigate. You don’t need to assert guilt—just raise the question and present the evidence.

 

🔗 Supporting Sources

• Homes of America Website
• PESP Vulture Wars Report
• MHAction Health Report – HOME SICK
• FTC False Advertising Overview
• Florida FDUTPA Summary

Would you like this argument distilled into a sidebar or legal risk summary for your next draft? I can also generate a mock consumer warning label based on the contrast between claims and evidence.

• Homes of America – Enhancing Affordable Housing in the U.S.

 

10) MHProNews notes that a longer Q&A thread with Copilot occurred that is linked here. Confirmation of that thread by Copilot is linked here. That said, to avoid possible confusion from some back and forth nuances with Copilot, it was asked to re-run its analysis. The Q&A below reflects that, and Copilot’s response follows.

Okay, Copilot, I’d like to try one more time to get a nice clean response to the original question in this thread. The working plan will be that this entire thread’s Q&As will be provided to you for verification purposes which will be included in the developing report. But I like to avoid reader confusion whenever possible. So, in this response to the original question in this thread, unless you think it is factually necessary do not mention the corrections from prior threads. Just give a clean, factually accurate FEA that responds to the original question. It will be a better reflection, IMHO on you and easier for the reader to follow. Serious researchers will have the full linked thread. Make sense? Go.

Absolutely, Tony. Here’s a clean, factually grounded, and reader-friendly Facts-Evidence-Analysis (FEA) response to your original question regarding the developing MHProNews report on JPMorgan Chase, Alden Global Capital, Homes of America, and the Private Equity Stakeholder Project (PESP).

 

🧠 Why Multi-AI Fact-Checking Matters

Using multiple AI models to cross-check a developing investigative report strengthens:

• Accuracy: Verifies quotes, figures, and source integrity.
• Transparency: Ensures proper attribution and reproducibility.
• Balance: Identifies framing gaps or rhetorical overreach.
• Credibility: Builds trust with readers and stakeholders.

This approach reflects best practices in hybrid journalism and investigative integrity.

 

✅ Source Verification and Documentation

1. Gemini Attribution

• The report clearly identifies Gemini 2.5 as the source of quoted AI commentary.
• The full Q&A transcript and screenshot are included and timestamped.
• Attribution is transparent and reproducible.

2. PESP and MHAction Content

• The report quotes and links the Vulture Wars report and related materials.
• Key figures—such as the $93M mortgage, 144 parks, and eviction counts—are sourced from PESP’s public documents.
• MHAction’s Home Sick health impact report is also cited.

3. Homes of America Website

• The report includes pull quotes from Homes of America’s mission and values page.
• These quotes are juxtaposed with documented resident harms and legal findings.

4. Outreach Documentation

• MHProNews’ outreach to Homes of America, Alden Global Capital, and JPMorgan Chase is timestamped and shown via screenshot.
• As of the report’s publication date, no public response has been found from any of the three entities.

 

🔍 Manufactured Housing Institute (MHI) Response

• No public statement, press release, or social media post from MHI was found addressing the PESP report or the allegations involving Homes of America.
• This silence stands in contrast to former MHI Chair Tim Williams’ assertion that:

• “We should respond to every story, refute every statistic, and make our case to the public.”
  📎 Williams Quote

 

🧩 FEA of the Report’s Structure and Impact

✅ Strengths

• Primary-source anchoring: PESP, MHAction, HIP, and JPMorgan documents are quoted and linked.
• Balance: Homes of America’s own promotional claims are included.
• Outreach: Documented and timestamped.
• AI transparency: Gemini prompt, model, and screenshot included.
• Legal caution: Uses “alleged” appropriately for claims involving MHI members.
• Cross-AI audit: Notes Grok’s non-response, Gemini’s input, and Copilot’s refinements.

🧭 Strategic Framing

• The report guides readers to consider whether MHI members—such as Homes of America—have ever been publicly condemned by MHI for predatory or illegal behavior.
• It invokes Marty Lavin’s insight:

• “Pay more attention to what a person or firm does than what they say.”

📚 Historical Continuity

• The report builds on MHProNews’ prior coverage, including the Esther Sullivan anniversary article: 📎 Past Is Prologue
• It reinforces the idea that consolidation harms and regulatory gaps are recurring patterns.

 

⚖️ Legal and Regulatory Implications

• The contrast between Homes of America’s promotional claims and documented resident harms may raise false advertising concerns under:
  • FTC Act Section 5
  • State consumer protection laws
  • Fair Housing regulations if protected classes are disproportionately affected
• The report also references potential violations of:

• Antitrust laws (e.g., price fixing, market manipulation)
• Hobbs Act (extortion under color of law)
• RICO statutes (racketeering)
• SEC/IRS rules for nonprofit accountability

📎 IRS Complaint Against MHI

📎 Antitrust Lawsuit Article

 

🔗 Key Source Links

• Draft Report PDF
• Outreach Screenshot
• PESP Vulture Wars Report
• JP Morgan Mortgage PDF
• MHAction/HIP Health Report
• Homes of America Website
• MHI Newsroom

Let me know if you’d like this formatted into a sidebar, infographic, or embedded into your next draft. I can also generate a visual timeline or legal risk summary if helpful.

— MHProNews notes that the PDF of the full thread is linked here. The screen capture that confirms Copilot confirming the accuracy of that thread here. —

Part of that thread included the following.

🦅 Alden Global Capital

🔍 No direct rebuttal or press release found from Alden Global Capital itself. However:

• PESP reports that Alden’s affiliate, Homes of America, pleaded guilty in a Michigan criminal case involving unlicensed park operations. The company was fined $25,000 and ordered to sell the property
• Alden has not issued a public statement acknowledging this conviction or addressing broader allegations in the Vulture Wars report

📌 Conclusion: Alden Global Capital has not publicly responded to MHProNews or PESP’s broader claims, despite legal developments involving its affiliate.

 

Summary

Entity	Response to PESP Report	Response to MHProNews Outreach	Notable Findings
Homes of America	❌ None found	❌ None found	Cited in Home Sick health report 1
JPMorgan Chase	❌ None found	❌ None found	$93M mortgage not publicly addressed 2 3
Alden Global Capital	❌ None found	❌ None found	Affiliate pleaded guilty in MI case 4

Let me know if you’d like this formatted into a visual infographic or embedded into your next draft.

• 1) Report examines public health impacts for tenants in Homes of America manufactured housing
• 2) Press Releases | JPMorganChase
• 3) Newsroom | JPMorganChase
• 4) Alden Global’s Homes of America pleads guilty in Michigan criminal case; must pay fine and sell property
• 5) New report delves into impact of Alden Global Capital’s investments in manufactured housing communities
• 6) Alden Global Capital – Private Equity Stakeholder Project PESP

11) There is much more that could be said about this topic. But that’s sufficient to deliver on the headline topics, as Copilot and Gemini both indicated. Additional information can be found in the articles linked herein or that follow below. Note that the report below is about much more than the 16th anniversary celebration, as both Gemini and Copilot indicated.

 

 

As of 12:17 PM ET, there have been no known responses to MHProNews from JP Morgan Chase, Alden Global Capital, or Homes of America.

12) MHProNews Programming and Housekeeping Notices. There are certain technical updates on the MHProNews website that are useful. Those will be addressed in the near term. They may require some temporary down time. If that update process goes longer than a day, once the site is back up, the articles for those days will appear as normal for the dates as normal.

 

 

 

 

 

More facts, fresh reports, more earnings call and corporate news insights are planned to be unpacked along with other investigations this weekend and next week. Stay tuned to the industry’s documented runaway #1 source for more “News through the lens of factory-built homes and manufactured housing” © “Industry News, Tips, and Views Pros Can Use”© where “We Provide, You Decide.” © This is the place for “Intelligence for your MHLife.” © Thanks be to God and to all involved for making and keeping us #1 with stead overall growth despite far better funded opposing voices.

 

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