In response to numerous inquiries that MHARR has received in recent weeks, industry members should be aware that the HUD manufactured housing program has recently modified the “Frequently Asked Questions” (FAQ) section of its internet website. The FAQ questions and answers now correspond with, repeat and mirror HUD assertions contained …
Manufactured Housing Association for Regulatory Reform
MHARR’s comprehensive comments in response to the proposed rule on “On-Site Completion of Construction of Manufactured Homes” published by HUD on June 23, 2010. MHARR, as with its comments on proposed rules concerning the “Duty to Serve Underserved Markets” and “Test Procedures for Roof Trusses”, has prepared and filed these …
Attached, for your information, review and use, are MHARR’s comments in response to the proposed rule on “Test Procedures for Roof Trusses” published by HUD on June 16, 2010. MHARR has prepared and filed these comments at an early stage in the rulemaking process so that they can be used as a model, basis, or support, as needed, for industry members who wish to submit their own comments. Comments in response to the proposed rule must be filed no later than August 16, 2010. Specific instructions for filing comments either electronically or via mail delivery are contained in the Federal Register notice at 75 Federal Register No. 115, June 16, 2010, page 34065, which can be accessed through the internet.
Washington, D.C., July 20, 2010 – The Manufactured Housing Association for Regulatory Reform (MHARR) has asked the Secretary of the U.S. Department of Energy (DOE), Dr. Steven Chu, to delay the development and implementation of costly new energy regulations that would have a devastating impact on an already ailing manufactured housing industry and its mostly lower and moderate-income American families.
Under the Energy Conservation and Security Act of 2007 (EISA), responsibility for the regulation of energy conservation in manufactured homes was shifted from the U.S. Department of Housing and Urban Development (HUD) – which comprehensively regulates manufactured housing construction and safety based on a careful statutorilymandated balance between regulation and cost to consumers — and transferred to DOE. The legislation directs DOE to establish new manufactured housing energy standards, by regulation, within four years of its enactment, based on the mandates of the International Energy Conservation Code (IECC).
After several years of delay, HUD has finally published a proposed rule to implement the second set of revisions to the Part 3280 Manufactured Housing Construction and Safety Standards processed and recommended by the Manufactured Housing Consensus Committee (MHCC). The proposed rule was published in the Federal Register on July 13, 2010. Written comments on the proposal are due on or before September 13, 2010.
HUD has published a proposed rule to revise its roof truss testing procedures under section 3280.402 of the Construction and Safety Standards. The proposed rule (copy attached) was published in the Federal Register on June 16, 2010. Comments from interested parties are due on or before August 16, 2010.
This matter has a long history, dating back to 2003, when the Manufactured Housing Consensus Committee (MHCC) first submitted proposed roof truss testing amendments to HUD as part of its initial package of recommended changes to the standards. The roof truss testing proposal, however, was
To start with some good news, indications are that the twelve year decline in manufactured housing production and sales may be leveling-off and, hopefully, coming to a halt. Just as importantly, an MHARR analysis, including input from manufacturers and retailers, shows that as the first signs of a possible recovery …
The release of a new FHA Title I Mortgagee Letter, designed to complete the implementation of the Title I program improvements approved by Congress in the Housing and Economic Recovery Act of 2008 (HERA), was announced by Federal Housing Commissioner David Stevens at the June 2,2010 manufactured housing industry finance summit meeting. The Mortgagee Letter, to be issued on June 2, 2010, will, according to HUD, pave the way for the development of guidelines by GNMA for the securitization of manufactured housing obligations and the qualification of finance institutions to provide FHA-insured Title I loans. &, Below).
A high-level summit meeting to address the financing issues that have fueled a prolonged industry decline and unprecedented hardships for consumers, was co-hosted by Congressman Joe Donnelly (D-IN) and HUD Assistant Secretary for Housing-Federal Housing Commissioner David Stevens in Elkhart, Indiana on June 2,2010. The meeting brought together industry leaders and high-ranking officials of government agencies — including HUD, the Federal Housing Administration (FHA), the Government National Mortgage Association (GNMA) and the Federal Housing Finance Agency (FHFA) — with a role in providing or supporting public and/or private consumer financing for manufactured homes
The Federal Housing Finance Agency (FHFA) announced, at the June 2, 2010 Elkhart, Indiana industry finance summit meeting, the release of its long-awaited proposed rule to implement the “duty to serve underserved markets” (DTS) provision of the Housing and Economic Recovery Act of 2008. The unofficial text of the proposed rule, which (as of June 3, 2010) has not yet been published in the Federal Register, is available through a link at the conclusion of the attached June 1, 2010 FHFA News Release announcing this action (see, attachment).
I. MHARR OFFICIALS MEET NEW HUD PROGRAM MANAGEMENT
MHARR officials, including members of the association’s Executive Committee and staff, met on May 24, 2010 with HUD Associate Deputy Assistant Secretary Teresa Payne, recently appointed the new manager of the HUD manufactured housing program.
Given the fact that manufactured housing finance issues are scheduled to be addressed in detail at a June 2, 2010 roundtable meeting in Elkhart, Indiana, being jointly hosted by Congressman Joe Donnelly (D-IN) and Federal Housing Commissioner David Stevens — a meeting that MHARR will attend and participate in — this first MHARR meeting with the new program leadership focused specifically on issues related to the Title VI manufactured housing program.
To: Concerned Members of the Manufactured Housing Consensus Committee (MHCC)
Thank you all for sharing your thoughts, concerns and observations regarding the rapidly deteriorating status of the MHCC. MHARR has fully reviewed and analyzed your comments, as well as input from within the industry regarding this very important matter, and offers the following suggestions for reversing the downgrading of this important forum for the manufactured housing industry and its consumers.
Set forth below for your review and information is a copy of a May 6, 2010 letter from Congressman Joe Donnelly (D-IN) to his congressional colleagues, requesting their support for a resolution that would honor manufactured housing and designate the third week of June 2010 as “Manufactured Housing Week.”
At press time, the Administration has taken a first step to reverse the free-fall of the HUD manufactured housing program by reassigning its career manager and opening the way for the appointment of a new non-career program Administrator. The appointment of a non-career Administrator is a “responsibility” of HUD under the Manufactured Housing Improvement Act of 2000 and the track record of the last several years clearly shows that such an Administrator, working with the governing Administration at the policy level, is essential to the full, proper and successful implementation of the reforms contained in all relevant laws including the 2000 reform law and the manufactured housing provisions of the Housing and Economic Recovery Act of 2008. The appointment of a new non-career Administrator, moreover, is an urgent priority because a full plate of critical program issues that have been neglected or mismanaged in recent years, urgently need to be addressed, beginning with an issue that directly impacts manufacturers and the cost of manufactured housing to the public — reform of the current procedural and enforcement regulation (P&ER) structure.
WASHINGTON – The Obama Administration today released questions for public comment on the future of the housing finance system, including Fannie Mae and Freddie Mac, and the overall role of the federal government in housing policy. The questions have been designed to generate input from a wide variety of constituents, including market participants, industry groups, academic experts, and consumer and community organizations. The questions will also be published in a Federal Register notice requesting public comments, and information on the process for submitting comments will be included in that notice.
With the continuing rapid decline of the HUD Code manufactured housing industry as a direct consequence of the near-total unavailability of purchase-money financing for consumers, through either public or private sources, job number one for the industry must be to ensure the implementation — as quickly as possible – of laws already on the books that offer new and expanded sources of consumer financing.
It appears that April 14, 2010 could be an important date for the housing and housing finance industries. In an April 14, 2010 announcement issued under the joint auspices of the Department of Housing and Urban Development and the Department of the Treasury (copy attached) — as further explained and detailed in related testimony by HUD Secretary Shaun Donovan before the House Committee on Financial Services (copy attached) — the Obama Administration has launched a process designed to bring about changes to both the public and private aspects of consumer home financing.
Recent reports regarding changes in the management of the HUD manufactured housing program have led to some confusion within the industry, warranting an analysis and evaluation by MHARR of all available information — in light of decisions made at the Association’s March 2010 membership meeting — with the following preliminary conclusions.