HISTORIC-Manufactured Home Industry KPIs with Clayton Homes-Champion Homes-Cavco Industries-Manufactured Housing Institute Insights. 50 State Shipments Data. Facts-Evidence-Analysis (FEA)

Production and shipment data are key performance indicators (KPI) for the manufactured housing industry, but also for RVs, automotive and other sectors too. But arguably another relevant KPI are lending approval and related financing data. One of the features of this report will be an eye-opening revelation, based on information made public by a Federal Register notice, CFPB and other sources shown herein that revealed manufactured home sales could potentially double or more in relatively short order based on current activity. The six word punch line? Know the facts; enforce existing laws. In Part I of this facts-evidence-analysis (FEA) are the most recent official HUD Code manufactured home production and shipment data for all fifty states, Washington, D.C. and Puerto Rico. While such production information is on occasion found in a public-facing Manufactured Housing Institute (MHI) article, those may require a specific search to find. What was once publicly revealed by MHI (see another example here), in more recent years (perhaps circa their website remake) became ‘member only.’ Their occasional reporting is often not visible through the MHI news or news landing page.  Neither does Clayton Homes (BRK), Champion Homes (SKY-previously known as Skyline Champion) and Cavco Industries (CVCO) commonly offer the general public monthly total U.S. manufactured housing industry new home production and shipment data. Beyond production/shipments, lending KPIs are included herein too. Stating the obvious can be clarifying: millions of documented affordable housing seekers have no massive political action committee (PAC). Meanwhile, Clayton, Champion and Cavco are each a member of MHI and the NAHB.  While there are multiple nonprofit groups that pose as advocating for the needs of lower-income Americans who want affordable housing, some of those groups have either sat silent or actively advocated for legislation that worked its way through Congress in recent years that claims to be the “21^st Century ROAD to Housing Act.” By contrast to the millions of consumers (see further below) who need and want affordable homes, there are corporate interests that apparently believe they benefit from the status quo, or so they effectively proclaim through their own publicly traded investor relations presentation or earnings call statements that have for years proclaimed their respective progress in industry consolidation. Among those are Clayton Homes (BRK), Champion Homes (SKY), Cavco Industries (CVCO) which are sometimes referred to as the 3Cs of the Manufactured Housing Institute (MHI). That longstanding 3C moniker arguably suggests that those three firms have some loose (or close?) working relationship. Some 6 years ago, Samuel Strommen, J.D., then at Knudson Law, made a seventeen-plus page argument including over 130 footnotes that pointedly asserted (bold added by MHProNews): “What was previously a top ten [in U.S. manufactured housing production] has amalgamated into a top three.” “Berkshire Hathaway and its subsidiaries’ anticompetitive behavior is quite clearly injurious to consumer, but in this matter, they are not alone. It would appear that Cavco Industries and Skyline Champion are willing [de facto allies].” “However, this begs the question not of the method but the mode by which the three industry leaders are using to accomplish this. The answer to that would appear to be the industry trade association, the Manufactured Housing Institute. The Manufactured Housing Institute [MHI] acts not only as the public mouthpiece of the Big 3 manufacturers (in the name of the industry) but also appears to act directly on its behalf in its various lobbying endeavors.⁹⁵”

But this facts-evidence-analysis (FEA) article is not about purported oligopoly style antitrust violations per se, but it is worth this paragraph to outline that topic. Strommen was hardly the first to make such an assertion of ‘monopolization’ or potential antitrust-violating behavior in manufactured housing involving MHI and some of their key members. Amy Schmitz, J.D., Doug Ryan, George Allen, and this Masthead are examples that pre-date Strommen’s evidence-backed allegations. Others followed from university researcher Maris Jensen, members of BIS.org, members of the Federal Reserve System, MHARR‘s Mark Weiss and others. Not to be overlooked is the pending national class action antitrust suit that involves 8 of their 11 named defendants which are apparently MHI members, with one of those MHI members reportedly offering to settle in a deal that will include documents and testimony. Rather than oligopoly style monopolization, this FEA model report is focused on information the Big Three, MHI, and others in that orbit which routinely do not provide the public which MHARR and MHProNews offer monthly free to the public. That begs the question. Why not? Why don’t MHI and/or their key members publicly provide the kind of market information or other KPIs that are provided in Part I below directly and free to the public? Hold those thoughts.

Executive Summary that follows is adapted from Part II, below.

The pre-publication manuscript is mathematically sound, logically consistent, and accurately sources its comparative metrics from regulatory data pools (CFPB, FHFA, and HMDA). The core thesis—that a normalization of financing approval structures to baseline conventional lending standards could expand the manufactured housing market by over 100%—is fully supported by the provided mathematical model. Additionally, the draft accurately details a long-standing disconnect within the industry’s Key Performance Indicators (KPIs). That includes the Transparency Gap: “The assertion that the Manufactured Housing Institute (MHI) isolates monthly economic and shipment updates behind a member wall matches verified trade habits. This stands in contrast to the public data models utilized by the NAHB, NAR, RVIA, and MHARR.”

1. The National Association of Realtors (NAR). The National Association of Home Builders (NAHB). The Recreational Vehicle Industry Association (RVIA-which includes both motorized and towable RVs). The Manufactured Housing Association for Regulatory Reform (MHARR). Those are just some of the trade groups that provide monthly, free public data on their respective industry’s production, shipments or sales.

2. But there is more that MHI and its allied members apparently do not provide.

Just based on current interest in manufactured housing, based on data provided in reports linked above and below, there could be significantly higher sales levels than is currently available.

3. Notice that the data and pull quotes below are from the post immediately above. This is what is achieved without a series image/education campaign. This is what is achieved without competitive DTS or FHA Title I type financing. This is what is achieved without zoning/placement barriers be removed. Per the CFPB (see context here).

The majority of applications for manufactured housing loans do not result in an origination. Only 27 percent of manufactured home loan applications resulted in the loan being financed, compared to 74 percent of applications for site-built homes. These differences remain even after controlling for credit score.

Extrapolating from the CFPB data, if those who apply for a manufactured home had the same approval rate as conventional housing shoppers then there would be an increase of 2.74074074x approved loans. The Federal Register said that the common range for chattel loan approvals in manufactured housing has been between 70 to 80 percent. MHI data ‘has shown that the share of new homes financed using personal property chattel loans hovers around 76%, while roughly 18% use traditional mortgages.’ [1]

4. Next, using a different source (the Federal Register information linked here) and extrapolating from it yields the following insights. Note that in 2024, 103,314 new HUD Code manufactured homes were produced according to official data collected for HUD as reported by MHARR. Using ‘back of the napkin’ calculations that apply that 76 percent of those homes were potentially financed using chattel lending, here is what that math would look like: 103,314 x .76 = 78,518.64. Next, hypothetically, what would the result have been if the Federal Register reported loan approval data for manufactured housing on chattel loans would have been the same approval rate as that source reported for conventional site-built housing? Meaning, instead of a “65.6% denial rate” for chattel HUD Code home loans “compared to just 8.8% for site-built homes.” Meaning, an additional 129,646 HUD Code homes would have been sold in 2024. Meaning that one change could have brought the potential 2024 total production level to 232,960 homes.

See the deep dive linked below based on the Federal Register’s market context.

5. Here is how GAIO on 6.28.2026 showed the math formulas for that conclusion shown above.

If chattel loan financing approval rates for manufactured housing matched conventional site-built housing, an additional 129,646 HUD Code homes would have been sold in 2024. This would bring the potential 2024 total production level to 232,960 homes.

• • Current Chattel Loan Approval Rate: \(100\% – 65.6\% = 34.4\%\) (or \(0.344\))
  • Target (Conventional) Approval Rate: \(100\% – 8.8\% = 91.2\%\) (or \(0.912\))

The full, auditable Q&A and response is linked here which demonstrates that if no more applications were taken than actually occurred that year, potentially 232,960 total HUD Code manufactured homes could have been sold nationally in 2024. That could be more than double what actually occurred. 

6. Note that this sort of finding falls under the JOB Description for manufactured housing corporate professionals to know these sorts of data points and their implication for their respective firms, or in the case of MHI, for what that math would mean for the industry that they claim to represent “all segments” of in their electronic and other statements. To be fair, as every seasoned manufactured home professional who knows their way around retailing would know, not every approved loan closes. That disclosure noted, that evidence-based formula nevertheless reveals the dramatic difference based solely on changing the financing outcomes.

7. More on the facts-evidence-analysis checks of the above and related are found in Part II, below.

Part I

Part II. Additional Facts-Evidence-Analysis (FEA) from Sources as Shown, plus More MHProNews Manufactured Housing Industry Expert Commentary

In no particular order of importance are the following.

1. From the transparent and auditable input-inquiry process linked here and confirmed for accuracy here with Google‘s artificial intelligence (AI) powered Gemini were the following findings.

Facts-Evidence-Analysis (FEA) Audit Report

This report provides a strict mathematical, logical, and structural audit of the pre-publication draft submitted for review. The evaluation checks the accuracy of calculations, verifying whether the presentation aligns with data from the Consumer Financial Protection Bureau (CFPB), Home Mortgage Disclosure Act (HMDA), and the Federal Housing Finance Agency (FHFA).

1. Mathematical Validation of the Core Thesis

The mathematical model simulates a scenario where manufactured housing chattel (personal property) loan applicants experience the same credit approval rates as site-built conventional mortgage applicants.

Step-by-Step Formula Audit

• Baseline Data Points:

  • Total 2024 HUD Code Production: 103,314 homes

  • Estimated Chattel Finance Share: 76% ($103,314 \times 0.76 = \mathbf{78,518.64}$ homes, rounded to 78,518)

  • Current Chattel Denial Rate: 65.6% $\rightarrow$ Current Approval Rate: 34.4% ($0.344$)

  • Target Conventional Mortgage Denial Rate: 8.8% $\rightarrow$ Target Approval Rate: 91.2% ($0.912$)

• Step 2: Total Application Pool Volumetric Calculation

  $$\text{Total Applications} = \frac{\text{Current Chattel Sales}}{\text{Current Approval Rate}} = \frac{78,518}{0.344} = \mathbf{228,250} \text{ Applications}$$

  Audit Status: 100% Mathematically Correct.

• Step 3: Target Sales Under Adjusted Approval Rate

  $$\text{Target Chattel Sales} = \text{Total Applications} \times \text{Target Approval Rate} = 228,250 \times 0.912 = \mathbf{208,164} \text{ Homes}$$

  Audit Status: 100% Mathematically Correct.

• Step 4: Additional Units Realized

  $$\text{Extra Homes Sold} = \text{Target Chattel Sales} – \text{Current Chattel Sales} = 208,164 – 78,518 = \mathbf{129,646} \text{ Homes}$$

  Audit Status: 100% Mathematically Correct.

• Step 5: Potential Total Optimized Production

  $$\text{Potential 2024 Production} = \text{Original Production} + \text{Extra Homes Sold} = 103,314 + 129,646 = \mathbf{232,960} \text{ Homes}$$

  Audit Status: 100% Mathematically Correct.

Extrapolation Multiplier Verification

The text notes that matching the conventional approval rate represents a 2.74074074x increase in approved loans.

Audit Note on Sources: The model correctly identifies two distinct, valid multipliers based on different data subsets: the 2.74x multiplier originates directly from the raw CFPB data (74% vs. 27% application origination rate), while the step-by-step calculation precisely follows the FHFA/Federal Register chattel denial parameters (65.6% vs. 8.8% denial rates). Both streams are internally cohesive and accurately derived from their respective source citations.

2. Part I Data Integrity Audit (IBTS Shipment & Production Tables)

The shipment and production matrices provided for April 2026 via the Institute for Building Technology & Safety (IBTS) are balanced and structurally sound.

Volumetric Totals Re-Aggregation

• Shipments: Single-Section (SW) 3,889 + Multi-Section (MW) 5,318 = 9,207 Total Units. Total Floor Volume = 14,579.

• Production: Single-Section (SW) 3,889 + Multi-Section (MW) 5,318 = 9,207 Total Units. Total Floor Volume = 14,579.

The individual state entries sum perfectly to the reported aggregate lines. The formatting successfully preserves proprietary developer metrics under the “States Shown (*)” row for states containing fewer than three active manufacturing plants.

3. Analysis & Structural Alignment

The draft accurately details a long-standing disconnect within the industry’s Key Performance Indicators (KPIs).

• The Transparency Gap: The assertion that the Manufactured Housing Institute (MHI) isolates monthly economic and shipment updates behind a member wall matches verified trade habits. This stands in contrast to the public data models utilized by the NAHB, NAR, RVIA, and MHARR.

• Antitrust & Consolidation Context: Referencing Samuel Strommen’s legal analysis regarding the transformation of the market into a consolidated environment dominated by Clayton Homes, Champion Homes (SKY), and Cavco Industries (CVCO) adds a crucial foundational layer to the report. It establishes a plausible economic motive for preserving the status quo: a lack of secondary market liquidity (via the GSEs’ failure to implement chattel Duty to Serve programs) acts as a protective barrier against low-cost lending competition.

4. FEA Audit Conclusion

The pre-publication manuscript is mathematically sound, logically consistent, and accurately sources its comparative metrics from regulatory data pools (CFPB, FHFA, and HMDA). The core thesis—that a normalization of financing approval structures to baseline conventional lending standards could expand the manufactured housing market by over 100%—is fully supported by the provided mathematical model.

Verified Plain Text Reference Links

• CFPB Manufactured Housing Finance Source Data: https://files.consumerfinance.gov/f/documents/cfpb_manufactured-housing-finance-new-insights-hmda_report_2021-05.pdf

• FHFA Duty to Serve Proposed Rule and Chattel Analysis: https://www.fhfa.gov/document/mh_chattel_2_a_narrative_2024.pdf

• MHProNews Primary Investigation Framework: https://www.manufacturedhomepronews.com/how-many-sites-do-housing-buyers-visit-before-taking-action-seminal-zero-moment-of-truth-digital-study-by-google-and-nar-manufactured-housing-and-conv-sales-projected-for-2026-fea/

2. Before pivoting to a facts-evidence-analysis by third-party AI powered Copilot, let’s consider more “human in the loop” (HITL) generated evidence from the following national HUD Code manufactured housing by year tables.

a)

Much of the shortfall in affordable housing production which fueled the current affordable housing crisis in the 21st century can thus demonstrably be attributed to that annual deficit between what was the average production from 1995-2000 to what has been the production in 2001-2025.

b) Using the historical data found here is the following.

c) But look again at that same historical data here through a different prism.

Those 11 brands are now only 3 brands-Clayton Homes (BRK), Champion Homes (SKY), and Cavco Industries (CVCO).  Here is how that 293,138 totals in 1998 for those 11 brands looks when compared to the total U.S. manufactured housing production in 2025. 293,138/102,738=2.8532578014. Meaning, that part of those “consolidated” 3 brands production are 2.85x the production for all of the U.S. in 2025. Restated, those 11 brands were 285 percent more total production then than manufactured housing in 2025.

Keep in mind that there were other brands consolidated, not just those shown. So, the difference is even more stark than what is shown above.

d)

e) From recent SimilarWeb data reported linked here, here, and here.

f. The above list of visits are per SimilarWeb for a single recent month. Per an applied ‘back of the napkin‘ extrapolation from NAR and Google data shown here, there are 3 to 6 websites most shoppers visit before taking action. That would be an average of 4.5 visits per housing shopper. Noting that there are going to be some investors, researchers, industry professionals and others who visit those sites above, it should also be acknowledged that there are potentially thousands of other manufactured housing websites for this or that retail-facing business. So, for ‘back of the napkin‘ purposes, that 3.971 million makes a useful stand in for retail interest when divided by 4.5 (the number of sites visited by shoppers, extrapolating from NAR/Google).

Here is that math.

3,971,831/4.5 = 882,629.111111

g) Again, because NAR/Google said that the typical shopper is engaged for about 10 weeks, consider the following. Using ‘back of the napkin‘ extrapolations of those various datapoints and sources, it would mean that there are about 5.2 times the above number shopping for a manufactured home. Here is how that math would look.

882,629.111111 x 5.2 = 4,589,671.37778

Meaning, it seems reasonable to think that over 4.589 million people were actively shopping for a HUD Code manufactured home in a recent 12-month period.

Yet only 102,738 manufactured homes were produced in 2025? This mashup of various facts reveals a mammoth ‘funnel’ of interested, but unsold prospects.

h) Once more, this should call into question MHI’s ‘education’ and ‘marketing’ related activates. Have any other MHI or MHI linked platform brought together these or similar data points to reveal just how poorly the manufactured housing industry is performing compared to say the automotive, RV, NAHB, or NAR to name but a few big-ticket sales industries and/or their related associations. Yet MHI has the chutzpah to market themselves for classes and education?

i) MHProNews observes that MHI’s leadership ought to be embarrassed by the mammoth opportunities vs. the paltry results, and if they aren’t, they arguably should be mocked and formally probed on multiple levels. 

3. From the input-inquiry process linked here in response to the developing draft of this article linked here, third-party Microsoft Bing‘s Copilot artificial intelligence (AI) provided the following findings.

Facts–evidence–analysis (FEA) check – verdict

The draft is factually solid, well sourced, and analytically coherent. Its core claims about manufactured housing KPIs, finance barriers, and the growth potential from normalizing chattel lending approval rates are consistent with primary data from FHFA, CFPB, HMDA, HUD, MHARR and related sources.

From your draft:

“One of the features of this report will be an eye-opening revelation, based on information made public by a Federal Register notice, CFPB and other sources shown herein that revealed manufactured home sales could potentially double or more in relatively short order based on current activity. The six word punch line? Know the facts; enforce existing laws.”

That framing is supported by the evidence.

Key factual pillars – accuracy check

1. FHFA/Federal Register – chattel vs site-built denial rates, interest rates, and shares

Your use of FHFA’s proposed Duty to Serve rule language is accurate:

“Borrowers, particularly those seeking personal property (chattel) loans, face a 65.6% denial rate compared to just 8.8% for site-built homes. Even when approved, these borrowers are often subject to higher interest rates—averaging 9.24% for personal property loans versus 6.63% for traditional mortgages—creating a ‘financing gap’ that frequently offsets the lower purchase price of the home itself.”

HousingWire’s summary of the FHFA proposal confirms those figures and the 70–80% share of new manufactured homes titled as personal property.

Plain-text links:

• FHFA proposed rule (Federal Register summary via HousingWire): https://www.housingwire.com/articles/fhfa-proposes-new-duty-to-serve-rule-chattel-loans-in-focus/ (housingwire.com in Bing)
• FHFA Duty to Serve performance/data page: https://www.fhfa.gov/duty-to-serve (fhfa.gov in Bing)

2. CFPB – 27% MH approval vs 74% site-built

Your draft states:

“Only 27 percent of manufactured home loan applications resulted in the loan being financed, compared to 74 percent of applications for site-built homes. These differences remain even after controlling for credit score.”

That is directly consistent with CFPB’s 2021 HMDA-based report on manufactured housing finance.

Plain-text link:

• CFPB “Manufactured Housing Finance: New Insights from the Home Mortgage Disclosure Act”: https://www.consumerfinance.gov/data-research/research-reports/manufactured-housing-finance-new-insights-from-the-home-mortgage-disclosure-act (consumerfinance.gov in Bing)

3. Manufactured housing as largest source of unsubsidized affordable housing

Your description that manufactured housing is the largest source of unsubsidized affordable housing in the U.S. matches HUD and CFPB language.

Plain-text link:

• CFPB report (see opening summary): https://www.consumerfinance.gov/data-research/research-reports/manufactured-housing-finance-new-insights-from-the-home-mortgage-disclosure-act (consumerfinance.gov in Bing)

4. MHI vs MHARR / NAHB / NAR / RVIA on public monthly data

Your claim that NAHB, NAR, RVIA, and MHARR provide monthly public production/shipments data, while MHI walls its monthly economic reports behind a member-only paywall, is consistent with MHI’s own site structure and with prior AI-checked findings you quote in the draft. The embedded Q&A screenshot correctly reflects that MHI’s “Monthly Economic Reports” are member-only, whereas MHARR and the other trade groups publish public-facing monthly data.

Plain-text links (illustrative):

• FHFA Duty to Serve dashboards (showing MH-related data): https://www.fhfa.gov/duty-to-serve/performance-data (fhfa.gov in Bing)
• MHARR site (public production reports): https://manufacturedhousingassociationregulatoryreform.org

5. Back-of-the-napkin growth model – math and logic

Your model that, if chattel approval rates matched conventional site-built approval rates, 2024 HUD Code production could have reached ~232,960 homes (vs. 103,314 actual) is mathematically consistent with the assumptions you state:

“Extrapolating from the CFPB data, if those who apply for a manufactured home had the same approval rate as conventional housing shoppers then there would be an increase of 2.74074074x approved loans…Meaning, an additional 129,646 HUD Code homes would have been sold in 2024. Meaning that one change could have brought the potential 2024 total production level to 232,960 homes.”

The GAIO breakdown you include—using a 34.4% current approval rate vs. 91.2% target, deriving ~228,250 applications, ~208,164 target approvals, and 129,646 extra homes—is internally consistent and correctly applied to the 103,314 total production figure.

The draft appropriately flags this as a “back of the napkin” scenario and notes that not all approvals close, which is an important caveat. Analytically, it’s a reasonable, evidence-based illustration of the scale of lost opportunity rather than a precise forecast.

Minor refinements / caveats

• Approvals vs. applications vs. production: You already acknowledge that not every approved loan closes. It may help to add one short clarifying sentence that this model assumes the same application volume and focuses on potential production, not guaranteed outcomes, to avoid misinterpretation as a hard forecast.
• Regulatory timelines and implementation: Where you reference FHFA’s proposed rule, you might briefly note that it is still in the comment phase and not yet implemented—though your draft already treats it as a proposal, not a final rule.

These are refinements, not corrections; they don’t undermine your core thesis.

Direct answer

The HITL draft is largely accurate, properly sourced, and analytically sound. Its key factual claims (denial rates, interest rate gaps, MH’s role as unsubsidized affordable housing, CFPB approval disparities, FHFA’s chattel focus, and trade-group data practices) are well supported by primary sources. The growth model is mathematically consistent with stated assumptions and appropriately labeled as a “back of the napkin” scenario. Any adjustments are minor clarifications rather than substantive corrections.

— MHProNews notes that the PDF of the response above by Copilot is linked here. The Copilot generated link to the above is here: https://copilot.microsoft.com/shares/q4gXA9iFpa1noTwBu5B2T The screen capture documenting Copilot confirming the accuracy of the above is here. —

4. To see the Gemini generated featured image in response to this developing draft and its headline posted below in a larger or full size, in many devices and browsers click here and follow the prompts.

There is always more to know, which is why more of the industry’s professionals have been once more documented as flocking to MHProNews at a documented rate of some 101x of the rate of those visiting MHI. Indeed, MHProNews has more readers than MHI and their allied news and bloggers combined. Some sell optics for the sake of a narrative. Here, we provide expert MHVille facts-evidence-analysis (FEA)

L. A. “Tony” Kovach

With credits, thanks, and contributions to those sources as shown herein.

eFax Number 1-407-604-6427

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Invitation for Feedback

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• Public officials
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