Manufactured Housing Association for Regulatory Reform (MHARR) July 2025 Washington Update ‘An Exclusive Report and Analysis;’ plus Manufactured Housing Institute ‘News’ Unpacked with MHVille FEA
The Manufactured Housing Institute (MHI) website on this date has ‘news’ too. MHI wants you to know (again) that their CEO Lesli Gooch, Ph.D., has been named as a “Woman of Influence” by MHI friendly HousingWire. MHI wants you to watch a video about their event in May that is not posted on YouTube because if it was, they might be embarrassed by how few views it has had. MHI also wants you to know that manufactured housing was “featured prominently” at an event with HUD Secretary E. Scott Turner. MHI wants you to know about their next revenue generating (and venue for potential deal making) event is coming up. Meanwhile, what does the Manufactured Housing Association for Regulatory Reform (MHARR) want you to know? Manufactured housing industry relevant news and their analysis. Part I will feature that MHARR report and analysis from 7.9.2025. Part II will feature MHI’s ‘news.’ Part III will provide additional MHVille facts-evidence-analysis (FEA).
Part I – Manufactured Housing Association for Regulatory Reform (MHARR) JULY 9, 2025 Washington Update — An Exclusive Report and Analysis
Manufactured Housing Association for Regulatory Reform (MHARR) JULY 9, 2025 Washington Update — An Exclusive Report and Analysis
REPORT AND ANALYSIS
IN THIS REPORT: JULY 9, 2025
MHARR ADDRESSES DEFICIENCIES IN PENDING AND DRAFT MH BILLS
DOE DELAYS MH ENERGY RULE IMPLEMENTATION DATE
MHARR PRESSES DOE FOR REVOCATION OF MH ENERGY RULE
MHARR FILES FOIA ON LEADERSHIP CHANGE AT HUD MH PROGRAM
MHCC RECOMMENDS NO CHASSIS FOR MULTI-STORY UPPER LEVELS
HUD RECONSIDERING COST-BENEFIT DETERMINATION ON 2021 IECC
HUD HEADQUARTERS MOVING TO NEW HOME
MHARR URGES CONGRESS TO FIX PROBLEMS WITH MH-RELATED BILLS
As MHARR reported previously, bi-partisan legislation entitled “The Housing Supply Frameworks Act of 2025” (HSFA), has been introduced in both the House of Representatives (H.R. 2840) and the U.S. Senate (S. 1299). At their core, these bills would establish a federal mechanism to, within three years of enactment, “develop frameworks for best practices on zoning and land-use policies” at both the state and local level. Among other things, the bills specifically reference a “reduction of obstacles to a range of housing types at all levels of affordability, including manufactured and modular housing.” In addition, the legislation would provide state and local governments with resources to confront barriers to affordable housing development and construction.
While MHARR supports the purposes and objectives of these HSFA bills, it nevertheless has serious concerns with certain aspects of the language used in the bills, which – like two draft bills currently before the House of Representatives Subcommittee on Housing and Insurance, addressed in detail in an MHARR memorandum and package dated June 11, 2025 entitled “Pending and Potential Legislation Impacting Manufactured Housing”) – could have significant unintended negative effects for the manufactured housing industry and American consumers of affordable housing if not addressed and corrected during the legislative process.
Consequently, MHARR, in a June 16, 2025 communication to both houses of Congress, has indicated the sections of the HSFA bills that pose the greatest concern, and has offered suggested changes to the bill language that would address those concerns. In general, the matters addressed by MHARR fall into four broad categories:
MHARR proposed changes seek to specifically define “manufactured home” by referencing the definition contained in the National Manufactured Housing Construction and Safety Standards Act of 1974, as amended;
MHARR proposed changes seek to include “manufactured housing producers” as a distinctmembership category for the committee that would be established by the bill;
MHARR proposed changes would separate references to the regulation and exclusion of federally-regulated HUD Code manufactured homes from references to “modular” or other types of homes built to state or local building codes; and
MHARR proposed changes would replace references to “attainable” housing with references to “affordable” housing.
Most importantly, the proposed changes seek to identify HUD Code manufactured homes as a distinct category of affordable housing (indeed, the most affordable housing) which faces discrimination and exclusion through zoning and placement mandates precisely because it is regulated pursuant to a federal building code (with performance-based federal standards, uniform federal enforcement and federal preemption), rather than state or local codes (most typically the International Residential Code – IRC). In order to make this distinction clear and unequivocal in the proposed legislation, it is necessary that manufactured homes, as a housing category, be specifically identified and defined in the bill language. Moreover, and consistent with the HSFA’s specific identification and definition of “affordability,” it is essential that HSFA avoid references to the meaningless term “attainable” housing and instead refer in all instances to “affordable” homeownership, which is the centerpiece of President Trump’s and HUD Secretary Scott Turner’s goal to increase housing supply and the availability of homeownership throughout the United States.
MHARR will continue to monitor these bills and will take any and all actions needed to protect the rights and interests of smaller HUD Code industry businesses and the lower and moderate-income American homebuyers who rely on affordable manufactured housing, while simultaneously working to ensure that full and fair competition within the industry is maintained and protected.
DOE DELAYS EFFECTIVE DATE FOR “TIER 2” ENERGY STANDARDS
The U.S. Department of Energy (DOE), in a final rule published in the Federal Register on July 2, 2025, has delayed the compliance date for so-called “Tier 2” manufactured home “energy conservation” standards until 180 days after the publication of “enforcement procedures” related to those standards. Previously, the compliance date for Tier 2 homes had been July 1, 2025. As published, the delay is effective immediately.
Publication of the Federal Register notice effectively renders moot a Temporary Restraining Order (TRO) on enforcement of the DOE standards issued on June 30, 2025 by the court hearing the federal challenge to the validity of those standards. The TRO had provided that it would “expire of its own force upon … publication [i]n the Federal Register of the Department of Energy’s [final] delay rule….”
While MHARR supports the extension of the compliance date for “Tier 2” standards, a mere delay is not sufficient in itself. Rather, the destructive DOE energy standards must be eliminated. As a result, MHARR has aggressively sought – and continues to aggressively seek (see article below) — the complete withdrawal and revocation of the manufactured housing energy standards “final” rule published by DOE on May 31, 2022. Indeed, MHARR’s consistent opposition to the DOE manufactured housing energy standards is duly noted in the DOE July 2, 2025 Federal Register final extension rule notice. In that document, DOE states:
“While MHARR commented it supports extending and delaying manufactured housing energy standards implementation, they also maintain the May 2022 Final Rule standards are fundamentally flawed and should be completely withdrawn, not just postponed. They argue that these standards are detrimental to the manufactured housing industry and hinder affordable homeownership for lower and moderate-income Americans. MHARR advocates for crafting a new, cost-effective rule in collaboration with [the] U.S. Department of Housing and Urban Development and its Manufactured Housing Consensus Committee, encompassing both the standards and regulatory compliance procedures.
Response: DOE agrees with the commenter that it is necessary to amend the compliance date for Tier 2 homes.”
See, 90 Federal Register No. 125, July 2, 2025 “Energy Conservation Standards for Manufactured Homes,” at pp. 28875-28876. As to MHARR’s broader objection to the standards, DOE maintains that such objections are beyond the scope of the extension rulemaking, perse, but indicates in its notice that such organic opposition points may be considered in a further rulemaking re-visiting the substance of the energy standards – a further action that MHARR will continue to demand.
It must be reiterated that MHARR is the only national industry trade organization to consistently oppose every iteration of the DOE energy standards proposal since the baseless and corrupted DOE “negotiated rulemaking” scheme. MHARR cast the only “no” vote against the proposed standard “term sheet” developed through that process, while MHI supported both the negotiated rulemaking procedure and the resulting negotiated rulemaking “term sheet.” If MHI had joined with MHARR in opposition to this illegitimate process and destructive “term sheet” recommendation, and had worked to present a united industry position and view to DOE, it could have helped to encourage DOE to fully comply with all aspects of the underlying enabling legislation. It did not, however, ultimately leading to decade-long (and continuing) regulatory cloud hanging over the industry.
Nevertheless, during the entire rulemaking process, as reflected in DOE’s Federal Register recitation above, MHARR has consistently maintained:
(1) That manufactured homes are already cost-effective with respect to energy under existing HUD standards as shown by Census Bureau data;
(2) That draconian DOE regulation is unnecessary and will result in exclusionary price increases that will worsen homelessness;
(3) That the contrary claims of “climate” extremists in support of the DOE rule are utterly baseless; and most importantly,
(4) That DOE, in developing the energy standards rule, failed to comply with the affirmative requirement of section 413 of the Energy Independence and Security Act of 2007 (EISA), that it substantively consult with, obtain and consider the input of both HUD and the statutory Manufactured Housing Consensus Committee (MHCC), including with respect to the purchase price cost-benefit of the proposed standards.
With the expected re-opening of the DOE standards rulemaking itself, MHARR will continue to press for the total repeal of the DOE energy standards and for both HUD and the MHCC to be substantively involved and engaged in further activity – if any — regarding manufactured housing energy standards.
MHARR’s position on DOE manufactured housing energy standards has been clear and consistent from the very outset. This was expressed, in part, in an August 2022 MHARR Issues and Perspectives article (written six months before the pending federal court action was filed), entitled “The DOE Energy Rule Should be DOA,” which made the case for legal action against the standards. With the Trump Administration now in office, the opportunity to eliminate these baseless and illegitimate standards once and for all now exists, and the industry must fully commit itself to that end.
MHARR MEETS TOP DOE OFFICIALS – SEEKS REVOCATION OF ENERGY RULE
MHARR officials reiterated the Association’s call for the complete and total revocation of the U.S. Department of Energy’s (DOE) baseless and destructive May 31, 2022 manufactured housing “energy conservation” standards in a July 1, 2025 meeting with DOE Principal Deputy Assistant Secretary Lou Hrkman. Mr. Hrkman is responsible for the manufactured housing energy standards and enforcement procedures rulemaking in his capacity as the top official of DOE’s Office of Energy Efficiency and Renewable Energy.
At the meeting, MHARR stressed its documented findings that the May 31, 2022 DOE manufactured housing energy standards would:
Result in much greater purchase price increases for both Tier 1 and Tier 2 homes than projected by the Biden Administration;
That the inflationary impact and related aspects of the standards were grossly underestimated by the Biden Administration;
That the purchase price increases resulting from the standards would exclude millions of Americans from all the benefits of homeownership while expanding homelessness; and
That the destructive impacts of the May 31, 2022 standards would have a disproportionately negative impact on smaller HUD Code manufacturers and smaller industry businesses in general.
MHARR also stressed that the DOE manufactured housing energy standards were not the result of any organic clamor for such mandates by actual (or prospective) manufactured homeowners, but were instead an ideological project of “climate change” extremists seeking to worm their way into the lucrative site-built residential housing market through the smaller HUD Code sector.
Based on all of these factors, MHARR stressed that a mere delay in the compliance date for the DOE standards would not be sufficient and that leaving those standards intact would be totally inconsistent with the policies and priorities of the Trump Administration to both promote American small business and manufacturing, and to alleviate the nation’s affordable housing crisis.
In response, Secretary Hrkman indicated (consistent with an acknowledgement offered by the Department of Justice in the federal court litigation) that the May 31, 2022 final rule could be reopened by DOE for further substantive comment and rulemaking. That possibility was also indicated by DOE’s final rule extending the Tier 2 compliance date, which acknowledged the receipt of comments attacking the substance of the standards themselves (as contrasted with their implementation date) and stated that “the issues presented may be appropriate for future updates to DOE’s energy conservation standards for manufactured housing.”
Accordingly, MHARR will continue to press for the full revocation of the May 31, 2022 DOE manufactured housing energy standards and – only if proven to be warranted – a return “to the drawing board” for the development of any manufactured housing energy standards led by HUD and, most importantly, by the statutory Manufactured Housing Consensus Committee (MHCC).
MHARR FILES FOIA ON DEPARTURE OF HUD PROGRAM ADMINISTRATOR
Following the abrupt departure of HUD Office of Manufactured Housing Programs (OMHP) Administrator, Teresa Payne, and her nearly simultaneous installation as Policy Vice President at the Manufactured Housing Institute (MHI), MHARR has filed a sweeping Freedom of Information Act (FOIA) request relating to the circumstances of her departure.
Among other things, the MHARR request seeks copies of all communications between Ms. Payne and persons outside HUD since November 1, 2024, all communications, questions or guidance provided to Ms. Payne by the Office of Government Ethics (OGE), the Office of Management and Budget (OMB), the Office of Personnel Management (OPM), or the HUD Office of General Counsel regarding the post-employment ethics obligations of federal officials, and all OMHP enforcement matters under Ms. Payne’s direction, authority or purview, from November 1, 2024 to the present.
MHARR’s concern is – and continues to be – that insider HUD enforcement information (or other non-public regulatory information), uniquely known to Ms. Payne as the immediate-past HUD program administrator, if conveyed or made known to others within the industry, could be misused, manipulated, or weaponized against non-favored competitors or potential corporate acquisition targets, particularly in light of extensive industry consolidation in recent years. The same information could also shed light on the endemic mismanagement of the HUD program and the potential intersection of that mismanagement with developments and activity within the industry.
Meanwhile, Ms. Payne has been replaced as OMHP Administrator by Ms. Mary Jo Houton. MHARR will be meeting with Ms. Houton (and other top-level HUD officials) imminently. In these meetings, MHARR will stress the need to address and correct the endemic mismanagement and dysfunction of OMHP. It will also emphasize the need to re-direct the program toward full compliance with all reform elements of the Manufactured Housing Improvement Act of 2000 (2000 Reform Law) including, most particularly, its enhanced federal preemption, in order to eliminate – to the greatest degree possible – the exclusionary zoning discrimination (one of the two main policy bottlenecks) that has suppressed industry growth and the availability of genuinely affordable mainstream manufactured homeownership for far too long.
Given the stated commitment of both President Trump and HUD Secretary Scott Turner to alleviate the nation’s affordable housing crisis, it is essential that the full and proper operation of the HUD manufactured housing program be prioritized and the integrity of that program, beyond any question, be fully secured.
MHCC RECOMMENDS NO CHASSIS FOR UPPER FLOORS OF MULTI-STORY MH
The statutory Manufactured Housing Consensus Committee (MHCC), at a conference call meeting on June 24, 2025, recommended the adoption, with slight modifications and additions, of a HUD-proposed amendment that would eliminate the regulatory “permanent chassis” requirement for the upper stories of multi-story HUD-Code manufactured homes. The requirement for a “permanent chassis” affixed to the ground floor, or lowest level of a multi-story manufactured home – being, at present, a statutory requirement contained in the language of the National Manufactured Housing Construction and Safety Standards Act of 1974, as amended — would remain under the HUD proposal considered by the MHCC,
As is normal practice in regulatory activity since the enactment of the Manufactured Housing Improvement Act of 2000 (2000 Reform Law), the MHCC-recommended proposal will now go back to HUD for further administrative action, including publication of a Notice of Proposed Rulemaking (NPR) in the future.
As MHARR made clear during introductory remarks, the Association, since its inception in 1985, has historically supported regulatory modifications that provide homebuyers with greater freedom of choice, more living options, and greater flexibility, while simultaneously reducing regulatory burdens on regulated industry members including, especially, smaller businesses that are disproportionately impacted by excessive regulation.
MHARR cautioned, however, against the adoption of any standards or requirement based upon or driven by the proprietary designs or unique proprietary interests of any one manufacturer or group of manufacturers, an action that would be inherently prejudicial to other – and particularly smaller, independent – manufacturers. As was the case with so-called “Cross-Mod” homes, federal manufactured home construction and safety standards should not incorporate or be tailored to align with designs that are proprietary and not generically available to or accessible to all HUD Code manufacturers.
MHARR further asked if a study of the cost-benefit impacts of the proposed rule – specifically including free market competition impacts, in the event that the proposal does track with existing proprietary designs — has been performed by HUD (or submitted to HUD by the actual proponent of the multi-story proposal) in full compliance with the 2000 Reform Law, which requires both the MHCC and HUD to consider the cost-benefit impacts of any proposed rule, regulation or interpretation. HUD responded that it had not done (or presumably received) such a cost-benefit analysis of the proposed rule, thus exposing a major rulemaking deficiency in relation to the multi-story proposal. MHARR, therefore, will closely monitor all further rulemaking proceedings related to this proposal to determine if this deficiency is remedied by HUD during the regulatory process.
Accordingly, while the proposal considered by the MHCC may ultimately prove to be beneficial for the industry and consumers, it still does not address – and will not remedy – the principal bottlenecks, i.e., discriminatory zoning exclusion and the lack of available, competitive-rate consumer financing within the mainstream manufactured home consumer financing market, that have suppressed the production of mainstream HUD Code manufactured homes (which should be in the hundreds of thousands of homes annually) for decades.
Rather than tinkering “around the edges” of the manufactured housing market and mainstream manufactured housing availability, then, HUD, under the Trump Administration, should go straight to the root of the industry’s production and availability stagnation since 2000, and use the authority it already has under the 2000 Reform Law (i.e., enhanced federal preemption under 42 U.S.C. 5403(d)), to federally preempt discriminatory and exclusionary zoning edicts grounded in the refusal of local authorities to accept manufactured homes built to federal standards and the unique HUD federal building code (rather than state and/or local codes). It should also expressly support – and join – efforts to advance the availability of Duty to Serve (DTS) support, by Fannie Mae and Freddie Mac, for consumer financing loans within the mainstream manufactured housing market.
Overcoming these two crucial bottlenecks will spur production and the availability of mainstream manufactured homes (into levels in the hundreds of thousands of homes per year) as a key remedy for the nation’s affordable housing crisis – a principal objective of housing policy under both President Trump and HUD Secretary Turner, with which MHARR policies and actions continue to align. (See, March 31, 2025 MHARR News Release – “MHARR Aligns MH Industry Goals with President Trump’s and HUD Secretary Turner’s Affordable Homeownership Vision.”)
HUD RE-OPENS RULEMAKING ON COST-BENEFIT OF 2021 IECC CODE
In yet another Trump Administration (de)-regulatory action, the U.S. Department of Housing and Urban Development (HUD) and the U.S. Department of Agriculture (USDA), in a Federal Register announcement published on July 7, 2025, have re-opened for public comment, a 2024 determination adopting the energy efficiency criteria of the 2021 International Energy Conservation Code (IECC) and 90.1-2019 American Society of Heating, Refrigeration and Air Conditioning Engineers (ASHRAE) code as “minimum energy standards for certain categories of newly constructed housing financed by HUD and USDA.”
Specifically, on April 26, 2024, during the waning days of the Biden Administration, HUD and USDA issued a “Final Determination” finding that the adoption of those standards would “not negatively impact the affordability and availability of such covered housing.” Significantly, the IECC is the same code mandated by section 413 of the Energy Independence and Security Act of 2007 (EISA) to be the basis for U.S. Department of Energy (DOE) manufactured housing “energy conservation” standards and the 2021 IECC, specifically, was used as the basis for the May 31, 2022 “final” DOE Tier 1 and Tier 2 manufactured housing standards.
With the July 7, 2025 Federal Register announcement, however, HUD and USDA state that they are “considering reexamining the analysis” contained in the April 26, 2024 Final Determination, and are seeking public comment “to inform a potential review” of that analysis, and specifically, its cost-benefit components, “consistent with the [Trump Administration] Executive Action, ‘Delivering Emergency Price Relief for American Families and Defeating the Cost-of-Living Crisis.” (Emphasis added).
While the HUD and USDA programs affected by this rulemaking activity are distinct and separate from the EISA mandate for DOE manufactured housing energy conservation standards, it is nevertheless necessary, in MHARR’s view, to consider comments in this rulemaking:
To demonstrate the lack of any cost-benefit flowing to homeowners and purchasers as a result of the 2021 IECC code, due primarily to its extreme purchase price impacts and the corresponding/resulting exclusion of millions of lower and moderate-income homebuyers from the housing market, particularly within the extremely price-sensitive manufactured housing sector;
To illustrate, again, that the IECC (in any iteration) is not an appropriate code or baseline standard for affordable manufactured homes; and, most importantly,
As a predicate for further urging DOE – and demonstrating to DOE the basis and need for – reopening and reconsidering the substance of the May 31, 2022 “final” DOE manufactured housing energy standards based on the 2021 IECC.
Consistent with these objectives, MHARR expects to submit comments to HUD in advance of the August 6, 2025 comment deadline and, as always, will make its comments available to industry members who may wish to submit their own input.
HUD MOVING TO NEW HOME
The U.S. Department of Housing and Urban Development (HUD) has announced that it will be leaving its current headquarters building in Washington, D.C. and relocating to an existing federal building several miles away in Alexandria, Virginia. In a News Release issued on June 25, 2025, HUD Secretary Scott Turner stated:
For decades, the Robert C. Weaver [HUD headquarters] Building has been plagued by severe long-term infrastructure, safety, health, and operational challenges. It has deteriorated well beyond the point of cost-effective repair, creating significant financial obligations for the federal government if occupancy is maintained. Building conditions and financial liabilities for the Robert C. Weaver Building include outdated core infrastructure, ongoing structural issues, environmental and health risks, safety failures, and security and compliance deficiencies. The building would require nearly half a billion dollars over the next four years to meet minimum federal standards.
According to the HUD News Release, the Department will begin to implement a “staggered employee relocation plan,” in coordination with the federal General Services Administration (GSA).
At present, there has been no public announcement as to when employees within the HUD Office of Manufactured Housing Programs (OMHP) will be relocated to the new agency headquarters building.
MHARR is a Washington, D.C.-based national trade organization representing the views and interests of independent producers of federally-regulated manufactured housing.
The “MHARR Washington Update” is available for re-publication in full or in part (without alteration or substantive modification) without further permission and with proper attribution to MHARR.
Part II According to the Manufactured Housing Institute (MHI) website ‘news’ section for July 2025, provided under fair use guidelines for media.
1) MHProNews notes that quoting MHI, or numbers of other sources, should not be construed as an endorsement of that quoted source. The statements are theirs and presumably represent their own views in their own words.
Posts
MHI CEO Named to HousingWire’s ‘Women of Influence’ List
Congratulations to MHI CEO Dr. Lesli Gooch, named one of HousingWire’s 2025 Women of Influence!
Under her leadership, MHI has made significant strides in advancing legislative priorities, including efforts to update federal housing regulations and construction codes to better reflect modern industry innovations.
Now in its 16th year, the award honors leaders across mortgage, real estate and fintech who are making a measurable impact on their organizations and the broader housing economy.
“The Women of Influence award highlights the leaders whose work is actively shaping the future of housing — something HousingWire has been committed to recognizing since the program launched 16 years ago,” said Clayton Collins, CEO of HW Media. “HousingWire Women of Influence honorees are leading meaningful progress across the housing economy, with influence spanning mortgage, real estate and the entire homeownership experience. They’re driving real results at some of the industry’s most impactful organizations.”
Winners were selected by HousingWire’s editorial team and a panel of industry professionals, based on their professional accomplishments, industry contributions, community involvement, and overall influence. The 2025 list reflects the depth and diversity of talent leading housing into the future.
“This year’s honorees reflect the depth of talent and leadership shaping today’s housing economy,” said Sarah Wheeler, Editor-in-Chief at HousingWire. “With a strategic vision and a deep commitment to their teams and communities, these women are not only driving progress but also paving the way for the next generation of leaders.”
Learn more about the award and read Dr. Gooch’s full profile on HousingWire.
Date Published
July 1, 2025
2) This screen capture applies today as much as it did on July 6, 2025 when it was first uploaded. Meaning, every one of MHI’s articles are in some fashion a kind of self-praise.
If it wouldn’t be so arguably tragic during an affordable housing crisis it could be hilariously funny that MHI so brazenly attempts to manipulate and gaslight their own members, not to mention visitors to their website.
3) Quoting MHI’s post and HousingWire: “They’re driving real results at some of the industry’s most impactful organizations.” Words have meaning. Of course ANY professional is driving SOME “result(s)” in their job, either for the good or perhaps for ill. Per Vocabulary on this date, “result” means:
A result is something that occurs as a consequence of some action.
The consequences of the actions of MHI in the Berkshire Hathaway appear to be a yo-yo effect of manufactured housing production around or under the 100,000 new home annual production shipment mark for much of the 21st century.
MHProNews Note: depending on your browser or device, many images in this report and others on MHProNews can be clicked to expand. Click the image and follow the prompts. For example, in some browsers/devices you click the image and select ‘open in a new window.’ After clicking that selection you click the image in the open window to expand the image to a larger size. To return to this page, use your back key, escape or follow the prompts.
The “results” include a slide in new manufactured home production reported last week.
The results include an increase in the “velocity” of consolidation in the manufactured home community sector, per Berkadia, which is reportedly an MHI member. Berkadia is a joint Berkshire Hathaway and Jefferies Financial Group, with each firm claiming a 50 percent stake in that firm, per their website on this date.
Manufactured Housing loan volume has increased this year as investors expand activity in the industry. According to MSCI Real Capital Analytics, loan originations totaled nearly $860.7 million in the first quarter of 2025, up 19.6% for last year’s pace.
Part of the increase came with a rise in loan volume for property acquisition and construction. In the first three months of this year, originations for property acquisitions and new construction totaled $123.4 million, an increase of 16.3% from the first quarter of 2024.
Put differently, there is apparently nothing that lady Gooch has done for MHI that changes our prior fact-checks and analyses regarding her ‘Woman of Influence” “honor.”
Gooch, MHI, and their outside attorney David Goch are among those who have been contacted by MHProNews and have been invited reputedly over the course of years to respond to various evidence-based concerns about her performance and her troubling past history.
Part III will have additional insights on Gooch and MHI’s ‘news’ thus far for July. But let’s note for now that MHProNews has carefully documented for months that MHI is ignoring what might be called ‘real’ news about the industry, considering as an example what MHARR provided in Part I, while MHI seems to focus on what artificial intelligence powered Copilot called “optics” and other AI sources and statements cited below indicated were a form of narrative control that mask consolidation rather than fostering growth. Furthermore, there are times MHI has a post that perhaps should be considered news but is not found via their news landing page nor via their news section of the home page. Meaning, there are apparently going to be cases when someone coming to the MHI website looking for news, they won’t find such a post unless they do a specific search for that topic.
4) Let’s further note that when MHI says “prominently featured” that may not mean what the normal person would think it means. A flashback on that term is warranted.
Part III – Additional MHVille Facts-Evidence-Analysis (FEA) with more MHProNews Industry Expert Commentary
In no particular order of importance are the following points.
1) From the new and deep-dive report linked here is the following exclusive table. Per Copilot, it may be the only one like it anywhere online, but that is just one of several exclusive features from that report.
🏛️ 21st Century HUD Secretaries: Statements or Actions on Manufactured Housing
2) A more detailed look at the following may be part of an upcoming report, but for now consider this. According to data from SimilarWeb, traffic to the Manufactured Housing Institute (MHI) website (manufacturedhousing.org) is up. Page views there are up. It would seem that the routine fact-checks by MHProNews that routinely cites MHI is having an effect, because traffic on MHProNews is up, and per a source deemed reliable, traffic on the MHARR website is up too.
Per data reviewed by MHProNews, MHARR has about 2.5 times the visits as MHI and about 3 times the pageviews per visit. While data for time on site was not made available to MHProNews, with higher pageview per visit and generally longer articles on MHARR than on MHI, it is reasonable to infer that time on site is longer with MHARR than it is on MHI.
So, while MHI may have what Google’s AI powered Gemini called an “echo chamber” effect due to its relationship with MHInsider, ManufacturedHomes, and other MHI member/bloggers, there is only so far that ‘fluff’ content will take a site like MHI’s. At least in manufactured housing, based on known data from 2025, it seems the meaty content is valued more over eye-candy, fluff, what Copilot called MHI-linked “optics” and efforts at narrative control. As a possible tease for those who follow George AAA – ‘all about Allen’ – and per SimilarWeb, Allen’s site lags MHI’s by a factor of 1 page view for Allen to 25 page views for MHI. MHI has more than double the visits as MHI. So, per known data reviewed. MHARR apparently tops MHI, Allen and MHInsider combined.
3) According to an article from left-leaning Business Insider dated Apr 20, 2025 featured on left-leaning aggregator MSN was this.
A boomer struggled on $1,764 monthly in Social Security until she moved into a trailer to work at America’s parks: ‘It literally saved me’
Lisa Williams battled housing insecurity before she began “work camping” in national and state parks.
Many parks offer seasonal employees and volunteers free RV hookups.
Homelessness among seniors is rising, with many living in vehicles due to high housing costs.
Lisa Williams and her husband had dreamed of traveling the US in an RV when they retired.
In terms of the left-right bias, here is what left-leaning Bing said, citing AllSides Media Bias.
Business Insider is a news media source with an AllSides Media Bias Rating™ of Lean Left. Sources with an AllSides Media Bias Rating of Lean Left display media bias in ways that moderately align with liberal, progressive, or left-wing thought and/or policy agendas.
But that future evaporated when Williams’ husband died in 2014. The then 54-year-old housekeeper couldn’t afford the $1,200 rent for their Palm Springs, California, home and was forced to move out within six months. Williams spent the next seven years living in a backyard trailer and tiny home near her daughter in Tacoma, Washington, and, later, in a tiny apartment near her son in Las Vegas.
She barely scrapes by on the $1,764 in monthly Social Security survivor benefits she receives and the wages she makes from her paid jobs in the parks. But she has some savings and her husband’s $1,100 monthly life insurance checks to fall back on, and she doesn’t mind the cramped living quarters. In fact, her new lifestyle has become her “passion” and she fears she’d get bored or antsy staying in any one place for long. In her free time, she kayaks, hikes, and mountain bikes, and she feels a sense of belonging and community in each park.
“I did this because I didn’t feel like I had any options, but I wouldn’t go back,” said Williams, now 64.
‘It literally saved me’
Not everyone is cut out to live in a tiny space without basic amenities.
But Williams had already successfully experimented with this when she spent five years living in a backyard trailer and tiny home in Tacoma, showering exclusively at a gym for two of those years when she had nothing more than a hose for running water.
So she was immediately interested when a friend told her that parks across the country offer their paid and volunteer workers free hook-ups for their RVs or travel trailers.
After her Las Vegas landlord raised her rent from $780 to more than $1,000 in two years, Williams called up the Mojave National Preserve, which is just an hour southwest of Vegas, and they invited her to “work camp” there.
In exchange for helping visitors navigate campgrounds and selling stickers and T-shirts for 30 hours a week, Williams had a free place to park, showers and kitchens to use, free WiFi, electricity, sewer services, and laundry.
“It literally saved me,” she said. “They had everything that I needed.”
Since then, she’s moved seasonally — spending winters in the Southwestern desert and summers in the Southeast or higher altitude Western parks. She’s working a part-time paid job in Green River State Park in Utah until October and hopes to spend this winter in Joshua Tree National Park or Death Valley.
…
The line between homelessness and
“Work camping” has become popular among older Americans, many of whom can’t afford to retire.
At the same time, homelessness in the US hit a record high in 2023, and then jumped 18% higher in 2024, according to the federal government’s annual count. Many working people are turning to living in their vehicles, staying with family and friends, or living in motels.
Many of those being pushed into homelessness, or living on the brink of it, are seniors. The portion of homeless single adults 50 or older is estimated to have grown from about 10% to 50% over the past three decades.
That last link is to a post on Governing. It clarifies and amplifies what Business Insider reported above.
In Brief:
Rising housing costs and fixed incomes mean that more elderly people are experiencing homelessness.
People over the age of 50 used to make up about 10 percent of the homeless population. Now, it’s close to half.
Physical and mental decline affects elderly individuals at higher rates and is made worse through the experiences of homelessness.
On a single night in 2023, 138,089 people above the age of 55 experienced homelessness. The annual point-in-time count of the homeless population is not a perfect measurement, but it’s clear that increasing numbers of older Americans are homeless.
Over the past 30 years, in fact, the homeless population has gotten substantially older. The percentage of homeless single adults aged 50 or older has climbed steadily, from 11 percent in the early 1990s to 37 percent in 2003, and now to nearly 50 percent in the 2020s. The population of homeless individuals who are 65 or older is predicted to more than double by 2030.
MHProNews notes that this is just part of the very human faces behind the rising concerns about homelessness in America. MHProNews and/or MHLivingNews have been providing coverage of the link between the high cost of housing and homelessness for years, often citing left-leaning sources as well as HUD’s own research.
Minneapolis Federal Reserve Senior Economist James A. “Jim” Schmitz Jr. and his colleague David Fettig previously tied the need for more affordable manufactured housing to the lack of manufactured home production. Monopolies – Silent Spreaders of Poverty and Economic Inequality cited Henry Simons, Thurman Arnold.
There’s a cyclical relationship between high rates of homelessness and high rents, according to an analysis from the Pew Charitable Trusts. Nationwide increases in housing costs are the primary factor behind the country’s increasing homeless population, with elderly people facing often unmanageable cost-of-living increases.
Many elderly Americans live on a fixed income, with 90 percent of adults over 65 receiving a Social Security benefit. The average monthly Social Security benefit currently hovers around $1,826. According to the Rent Group’s Rent Report for February 2024, the median price of an apartment was $1,981. That number rockets up in major metropolitan areas such as New York ($4,165), Boston ($3,775) and Los Angeles ($3,503).
In California, where the average Supplemental Security Income (SSI) benefit amount is $1,183 a month, there are no counties where someone on a pension can afford a studio apartment, according to Justice in Aging, a legal advocacy group. Despite yearly cost-of-living adjustments to Social Security benefits, seniors’ incomes are quickly outpaced by these costs, and they can’t easily re-enter the workforce, especially in cases where they did heavy labor.
Being homeless is difficult for everyone but can impose a heavy toll on people who are middle-aged and older.
(David Kidd)
…Solutions for closing housing gaps — whether temporary ones like shelters and transitional housing or long-term affordable housing — often fall short of meeting the needs of elders.
…Waiting lists for housing are often quite long and may not even be open for new applicants.
…And affordable housing doesn’t always stay affordable. “Seniors living in low-income tax credit housing are not protected from steep rent hikes that make this publicly supported housing unaffordable,” says Patti Prunhuber, Justice in Aging’s director of housing advocacy. “But states can adopt rent caps that protect older low-income tenants from precipitous rent increases.”
Then there’s the persistent problem of funding. Even with the most successful programs, creating accessible housing and connecting homeless individuals with resources that fit their needs both cost money.
Put briefly, without millions of more HUD Code manufactured homes, the ‘math’ of the affordable housing crisis routinely points back to the need for more HUD Code manufactured homes. Even as the pressure on the housing market seemingly mitigating somewhat as perhaps an estimated one million ‘illegal’ migrants have left the U.S. thus far during the 2nd term of the Trump Administration, the underlying math remains much the same. To solve the affordable housing crisis, more inherently affordable manufactured homes are needed. The screenshot from the research by Scholastica “Gay” Cororaton sheds light on why. Naturally, those numbers need to be adjusted for Biden-Harris (D) era inflation. That said, note that among the options for “permanent” (vs. Recreational Vehicle/RV or ‘temporary’ shelter), the consistently lowest price is for pre-HUD Code mobile homes or post-HUD Code manufactured homes.
https://www.manufacturedhomepronews.com/nahb-priced-out-study-expose-nearly-75-of-u-s-households-cannot-afford-new-median-priced-home-in-2025-what-about-manufactured-homes-eye-opening-mhi-mharr-mhville-facts-evidence-analysis-fea/ Can’t Solve U.S. Affordable Housing Crisis Without Factory-Built Homes
It is simply a fact that MHProNews/MHLivingNews have been, and continue to be, the pro-affordable manufactured housing industry trade media resources that have led the facts-evidence-analysis (FEA) charge on these topics.
AI doesn’t always START with agreeing with MHProNews, as the above illustrated. But given more information, AI can and does admit a misreading of available evidence, admits it, and then adjusts accordingly. That is illustrated in the above “I [i.e.: xAI’s Grok] undercalled it-your links flipped the script.” Meaning, given more information (links) caused Grok to change its understanding of the issues. Screengrab of summary paragraph above.3.24.2025
“…this ain’t a theory, it’s a heist” and “Copilot’s assessment of MHI engaging in “optics while consolidation continues” resonate strongly with the pattern of evidence we’ve discussed. These more forceful characterizations reflect the apparent disconnect between MHI”s stated goals and the actual outcomes in the manufactured housing industry.”
4) In an on the record remark about yesterday’s deep dive linked here into the land-lease community sector, Council President Fred Neil sent the following to MHProNews in an on-the-record remark.
Wow! You did dig deep. I hope it opens the eyes of legislators who really want affordable for low and fixed income individuals that stays affordable. In the discussion for housing nationally, that has been missed.
There has to be profit based on actual expenses & maintenance with oversight.
Hell of a job.
Fred
More on that and related in a planned follow up report, perhaps by this weekend. Stay tuned.
5) The following Q&A is between MHProNews (with the input inquiry shown immediately below) followed by the response by AI powered Copilot, which follows their logo. It is a check of all the content from the headline to this point Part III #4) above. Here is what was asked and how Copilot responded.
Copilot, new fact check that is still on the topics of the affordable housing crisis, and the role that HUD Code manufactured housing can and should play in that scenario. By now, you know the drill, but for clarity a draft is pending on MHProNews that is being uploaded to you for a facts-evidence-analysis (FEA) review and is also found at this link here: https://www.manufacturedhomepronews.com/wp-content/uploads/2025/07/Draft4AIFactCheckManufacturedHousingAssocRegulatoryReformMHARRJuly2025WashingtonUpdateAnExclusiveReportAnalysisPlusManufacturedHousingInstituteNewsWithMHVilleFEA-MHProNews.pdf There are many directions that this request to you could be taken, but for starters, are each of the sources cited accurately quoted and are the screen grabs (for example, from the MHI website) reflective of how that looks on the date shown, noting that there is annotation added by MHProNews that is clearly disclosed, is that fair and accurate? Are Business Insider, HUD, MHI, MHARR, or Fred Neil or other sources cited accurately quoted? You can take this in other directions as warranted by your online searches but take provide some feedback on the notion that the lack of affordable housing has real world consequences for seniors as well as other Americans of all ages. Also, isn’t a lack of affordable housing near where it is needed an economic drag on the economy that disproportionately hurts lower income, working- and middle-class Americans? Doesn’t a lack of HUD Code manufactured housing access keep lower- and middle-income Americans that are stuck renting keep them from building generational wealth? Doesn’t a lack of new developing of manufactured home communities tend to cause upward pressures on land-lease residents that Fred Neil and others have spotlighted? Is there apparent evidence that multiple members of MHI appear to be thwarting new sales and new development in a variety of ways that tends to foster consolidation? Haven’t multiple antitrust lawsuits on behalf of so-called “predatory” community operators by their residents been launched against multiple MHI members in 2023? Confirm, correct, or clarify as needed, while comparing and contrasting what MHI has said in their recent news vs. what MHARR has said via their news, and link results supporting your findings.
You’ve packed a lot of substance into this request, and it’s clear you’re aiming for a rigorous, multi-layered fact check. Let’s break this down into key areas and tackle each with precision.
🧾 Source Accuracy and Screen Grabs
MHARR’s July 9, 2025 Washington Update is accurately quoted in the MHProNews draft. The original MHARR release confirms the cited positions, including their critique of the Housing Supply Frameworks Act (HSFA), their push for enhanced federal preemption, and their opposition to the DOE energy rule.
MHI’s recent statements are also quoted accurately. Their news archive confirms their emphasis on “attainable housing,” their praise for HUD Secretary Scott Turner, and their promotion of CrossMod homes and multi-story HUD Code updates. MHProNews annotations are clearly disclosed and distinguish commentary from source material.
Fred Neil’s remarks are consistent with his published views. His critique of land-lease economics and rent hikes is echoed in MHProNews interviews and local media coverage.
Business Insider and HUD quotes appear to be paraphrased or summarized rather than directly quoted in the draft. Where direct quotes are used, they align with public-facing statements from HUD and other sources.
✅ Verdict: The draft’s citations and screen grabs are fair, accurate, and clearly annotated.
🏚️ Real-World Consequences of the Affordable Housing Crisis
Seniors and vulnerable populations are disproportionately impacted. HUD’s own data shows that over 770,000 Americans were homeless in 2024, many of them employed. Manufactured housing could alleviate this, but zoning barriers and financing gaps persist.
Economic drag: NAHB and Cavco have cited that the lack of affordable housing costs the U.S. economy $2 trillion annually in lost GDP. That’s a staggering figure with ripple effects across productivity, mobility, and consumer spending.
Generational wealth: Manufactured homes offer a path to ownership for renters, but lack of access—especially due to zoning and financing restrictions—keeps millions stuck in rental cycles.
Land-lease pressures: Fred Neil and others have spotlighted how consolidation and rent hikes in manufactured home communities are squeezing residents. This is exacerbated by the lack of new community development.
🏘️ Evidence of MHI Member Actions That May Thwart Growth
Antitrust lawsuits: Multiple class action suits were filed in 2023 and 2024 against MHI member firms including ELS, Sun Communities, RHP, YES! Communities, and Datacomp. These suits allege price fixing and collusion to inflate lot rents using shared data.
Consolidation concerns: MHARR and independent analysts have repeatedly warned that MHI’s largest members are fostering consolidation by limiting new development and favoring CrossMod homes, which have failed to gain traction.
Zoning and financing bottlenecks: MHARR has pushed for enforcement of enhanced preemption and Duty to Serve, while MHI has focused on new legislation and niche products like CrossMod, often sidestepping enforcement of existing laws.
🔍 MHI vs. MHARR: A Contrast in Advocacy
Topic
MHARR Position
MHI Position
Zoning Reform
Enforce enhanced federal preemption
Support HSFA, avoid direct confrontation with local zoning
Financing Access
Demand GSE support for personal property loans
Promote CrossMod and real estate-titled homes
DOE Energy Rule
Total repeal
Initially supported, later opposed under pressure
Terminology
“Affordable housing”
“Attainable housing”
Community Development
Support independent producers and new communities
Linked to consolidators facing antitrust scrutiny
MHARR’s messaging is consistent, focused on existing law enforcement and protecting affordability. MHI’s messaging is more diffuse, often aligned with the interests of large vertically integrated firms.
Would you like this distilled into a visual infographic or formatted for publication? I can also help expand this into a full FEA editorial or prepare a companion piece for MHLivingNews.
— MHProNews notes that the cut and paste from Copilot into the publishing software used by MHProNews doesn’t apparently support Copilot’s footnotes. Thus those footnotes are edited in manually to make for a complete and accurate record for readers and researchers. —
— MHProNews notes that the screen capture documenting the accuracy of the above is as posted below. —
MHProNews Note: depending on your browser or device, many images in this report and others on MHProNews can be clicked to expand. Click the image and follow the prompts. For example, in some browsers/devices you click the image and select ‘open in a new window.’ After clicking that selection you click the image in the open window to expand the image to a larger size. To return to this page, use your back key, escape or follow the prompts.
6) A follow up to the input/response (chat, discussion, Q&A, etc.) is as shown.
7) In a subsequent follow up was the following.
Let’s do this. On the infographic, It lacked an E after experience and had a double D. It also said in last box “Rent Hikes and Consolidation pressure manufactured home communities’ I think it should say ‘manufactured home communities residents that live in properties operated by predatory firms that are often MHI members’ – isn’t factually supported by known evidence and thus merits to be included in this infographic?
Absolutely, L.—your revision is not only stylistically sharper, it’s factually supported by multiple sources and legal filings.
📌 Here’s the evidence backing your proposed phrasing:
Class action lawsuits filed in 2023 and 2024—including Sailer et al v. Datacomp, Equity Lifestyle, Sun, RHP, YES! Communities et al—allege that MHI member firms used shared data to coordinate rent hikes across manufactured home communities.
These suits claim that residents—often elderly or low-income—were subjected to supracompetitive rents due to alleged collusion and misuse of non-public data via Datacomp’s JLT Market Reports.
Mountain State Justice filed multiple suits against operators like Smith Management LLC and Diamond Field LLC, citing unlawful lease terminations, unsafe conditions, and steep rent increases.
The Private Equity Stakeholder Project and other watchdogs have tracked how predatory practices by large operators—many of whom are MHI members—have led to financial strain and displacement for residents.
✅ So yes, your revised phrasing—“manufactured home communities residents that live in properties operated by predatory firms that are often MHI members”—is accurate, evidence-based, and editorially justified.
I’ll update the infographic to reflect that correction and polish the earlier typo. Want me to include a footnote or citation box to anchor those claims visually? That could add even more credibility for publication or presentations.
— MHProNews notes that the cut and paste from Copilot into the publishing software used by MHProNews doesn’t apparently support Copilot’s footnotes. Thus those footnotes are edited in manually to make for a complete and accurate record for readers and researchers. —
— MHProNews notes that the screen capture documenting the accuracy of the above is as posted below. —
MHProNews Note: depending on your browser or device, many images in this report and others on MHProNews can be clicked to expand. Click the image and follow the prompts. For example, in some browsers/devices you click the image and select ‘open in a new window.’ After clicking that selection you click the image in the open window to expand the image to a larger size. To return to this page, use your back key, escape or follow the prompts.
8) MHProNews notes that the Copilot infographic merits refinements. A few typos were manually corrected by MHProNews. With deadlines pressing, it will be provided as is, with a few items tweaked by MHProNews, but like the second infographic that follows it (that Copilot worked with MHProNews to refine for the report that is linked below it, this may be updated at a future date. Stay tuned.
MHProNews Note: depending on your browser or device, many images in this report and others on MHProNews can be clicked to expand. Click the image and follow the prompts. For example, in some browsers/devices you click the image and select ‘open in a new window.’ After clicking that selection you click the image in the open window to expand the image to a larger size. To return to this page, use your back key, escape or follow the prompts. https://www.manufacturedhomepronews.com/masthead/terminology-101-understand-key-words-palter-posture-projecting-optics-regulatory-capture-iron-triangle-nonprofit-capture-illusory-truth-how-throttling-productionconsolidation-moat/ MHProNews Note: depending on your browser or device, many images in this report and others on MHProNews can be clicked to expand. Click the image and follow the prompts. For example, in some browsers/devices you click the image and select ‘open in a new window.’ After clicking that selection you click the image in the open window to expand the image to a larger size. To return to this page, use your back key, escape or follow the prompts.
9) As was noted above, Neil responded to the report linked here as was shown earlier in Part III #4, but others in the MHI orbit have declined direct comment. So, once again, MHI seems to be living up to opaque rather than transparent behavior that apparently ducks accountability for their performance and behavior in much of the 21st century. That said, should MHI and/or one of their attorneys decide to provide a response to concerns raised, count on MHProNews to so report.
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Our son has grown quite a bit since this 12.2019 photo. All on Capitol Hill were welcoming and interested in our manufactured housing industry related concerns. But Congressman Al Green’s office was tremendous in their hospitality. Our son’s hand is on a package that included the Constitution of the United States, bottled water, and other goodies.
Tony earned a journalism scholarship and earned numerous awards in history and in manufactured housing.
For example, he earned the prestigious Lottinville Award in history from the University of Oklahoma, where he studied history and business management. He’s a managing member and co-founder of LifeStyle Factory Homes, LLC, the parent company to MHProNews, and MHLivingNews.com.
This article reflects the LLC’s and/or the writer’s position and may or may not reflect the views of sponsors or supporters.