Manufactured Housing Institute Gives ‘Updates’-Urban Infill CrossMods®, Claim New ‘Production Up’ Pitch Membership-Meetings Ed-Spending on MHI in 12.6.2023 Email; plus MHVille Markets


Perhaps someday public officials and/or plaintiffs’ attorneys peering into the woes hobbling the manufactured housing industry will consider if emails like the one below from the Manufactured Housing Institute (MHI) violated RICO. The Jeffrey Grell law firm says under the heading: “Mail and Wire Fraud. The extensive use of RICO in the civil context is almost solely attributable to the inclusion of mail and wire fraud as predicate acts.” (Italics and bold are added). Robert Helfand Law said similarly: “Wire fraud is a federal crime that involves any scheme to defraud another person or party by means of electronic communication.” A misuse of emails and websites can be among those “electronic communications” which can draw civil and/or criminal RICO charges. Per Troutman Pepper law: “the federal government does prosecute people for RICO using mail and wire fraud.” “Wire and mail fraud generally involves defrauding or attempting to defraud someone of money or property through using some form of interstate communication,” according to the Carmichael, Ellis & Brock law firm.

Top MHI corporate board, staff, and attorneys were asked once again on 12.7.2023 to respond to recent or previous reports on MHProNews and/or MHLivingNews. As regular, detail-minded readers here know, from time-to-time MHProNews asks MHI top staff, corporate leaders and/or their attorneys to provide feedback on published reports. In the request yesterday, that included the report on production related information linked here, the billions being spent on 3D printed housing and/or factory-built housing alternatives to manufactured housing linked here, and the deep dive critique of MHI linked here.

Among what MHI leaders were provided for comments includes information from MHI a couple of weeks ago that compared what they claimed to other known facts and evidence. MHI leaderhip’s and legal mind’s answer for each of those topics and reports, as well as others? Silence.

That silence is despite the fact – or perhaps because of a strict understanding of what outside MHI attorney David P. Goch said in the quote here.

In their email earlier this week to manufactured housing industry members and others on that email list, MHI gives no actual data to nonmembers who received that email. It claimed under the headline “MHI Economic Report: Production Up, Shipments Down.”

That’s arguably classic paltering, posturing, and propaganda. How can production be ‘up’ but shipments down? In MHI’s worldview, you must buy an MHI membership in order to find out. See for yourself further below in Part I.

In that section of their email, MHI doesn’t say ‘where’ production is ‘up.’ Is it up in certain states, but not others? Or is it up in some technical sense? Because year over year, manufactured home production is down. Perhaps MHI leaders hope those readers don’t get emails from the Manufactured Housing Association for Regulatory Reform (MHARR), which provides that information monthly free of charge, as has MHProNews. More on that and other topics from MHI’s email shown in Part I will be unpacked in Part II.

But in fairness to MHI, and for the ease of our readers getting the ‘full context’ of MHI’s remarks on 12.6.2023, here are the first elements of their message.


Part I – MHI Email Dated 12.6.2023


News and Updates

Clayton, GMHA Introduce 2 Urban Infill CrossMods® to Atlanta

Clayton and the Georgia Manufactured Housing Association unveiled a new urban infill project showcasing two Clayton Built® CrossMod® homes, the first of their kind within the Atlanta perimeter.

CrossMod® homes combine off-site construction with site-built features, making them indistinguishable from a traditional site-built home.

“It is critical that we find ways to increase attainable homeownership in cities across the nation, and the acceptance of CrossMod® in Atlanta is a major step toward accomplishing that goal,” said Ramsey Cohen, Director of Industry and Community Affairs at Clayton.

CrossMod® homes are built off-site in home building facilities and finished on-site with a foundation, garage and porches.

The Georgia Manufactured Housing Association (GMHA) helped the team secure a building variance from the City of Atlanta to place the home within city limits. Then, when the project lost its primary investor, the GMHA stepped up to finance the project.

“We looked at this as GMHA literally putting our money where our mouth is when it comes to advancing manufactured housing,” said GMHA Executive Director Jimmy Cotty.

Cotty said GMHA will build on the excitement of the Atlanta project and hopes to support future urban infill manufactured home projects in other parts of Georgia.

MHI Economic Report: Production Up, Shipments Down

Earlier this week, MHI released the October Economic Report. MHI members can read the full details of the report. Learn more about membership here.

News from Washington

House Energy and Commerce Committee Passes Legislation To Remove DOE Authority over Manufactured Housing Energy Standards

On Tuesday, the House Energy and Commerce Committee voted to pass the “Affordable HOMES Act” (H.R. 6421). The Affordable HOMES Act repeals Section 413 of the Energy Independence and Security Act (EISA) of 2007 and would ensure that the Department of Energy’s (DOE) final rule on Energy Conservation Standards for Manufactured Housing will have no force or effect.

Halting implementation of the EISA’s flawed approach and re-affirming HUD’s long-standing exclusive control over federal manufactured housing standards is the best way to ensure the timely adoption of improved energy efficiency standards for factory-built housing in a way that preserves the availability of affordable manufactured homes for American households. MHI has prepared a series of talking points to support voting “Yes” on the Affordable HOMES Act.

MHI supports the passage of the Affordable HOMES Act and asks for your support by going to the MHI Advocacy Action Center and telling your representative in Congress to support the passage of the “Affordable HOMES Act” (H.R. 6421). Congress must hear from all sectors of the manufactured housing industry about the urgent need to stop DOE overreach.

Connect with your Representative by following the simple steps on MHI’s website. MHI wrote a letter that you can send by simply inserting your home address and clicking submit.

MHI’s email also included a pitch for their for a fee (you or an organization paid for) “education” as well as their for a fee events.  As the MHI form 990 reveals, MHI events are a revenue generating center for the Arlington, VA based national manufactured housing trade organization.  Note that showing MHI content is NOT an endorsement of the organization. Some links have been modified in the above, but the text is as emailed by MHI.

Part II – Additional Information with More MHProNews Analysis and Commentary

On 12.4.2023, MHARR said the following. “Just-released statistics indicate that HUD Code manufacturers produced 8,393 new homes in October 2023, a 3.4% decrease from the 8,649 new HUD Code homes produced in October 2022. Cumulative production for 2023 is now 75,040 homes, a 23.8% decrease from the 98,506 homes produced over the same period during 2022.”

On 11.3.2023 MHARR stated: “statistics indicate that HUD Code manufacturers produced 7,955 new homes in September 2023, a 15.2% decrease from the 9,381 new HUD Code homes produced in September 2022. Cumulative production for 2023 is now 66,647 homes, a 25.7% decrease from the 89,812 homes produced over the same period during 2022.”

In normal English and typical mathematics, MHI’s claims of “Production Up” might be thought to imply that production is up “nationally” as they are a “national” trade organization, as they themselves state on 12.7.2023 on the home page of their recently revised website. “The Manufactured Housing Institute is the only national trade organization representing all segments of the factory-built housing industry. We are your trusted partner, advocate and industry leader.” But the first sentence before those two and those pesky facts above and that will follow contradict this MHI homepage claim: “Elevating Housing Innovation; Expanding Attainable Homeownership.”

But if homeownership were ‘expanding,’ as their tag line suggests, then why is national manufactured housing production falling?

If you happen to be an MHI member and/or are at an event where they happen to be, and you are feeling brave enough, why not ask one or more of them at a manufactured housing event or meeting? If you can, record the Q&A, and let us know what they tell you.

MHARR is not in the misdirection or deception business. MHARR provides facts, MHARR leaders share evidence, and then MHARR leaders take facts, evidence, the law and clearly draw reasonable conclusions.

MHARR is led by an attorney, Mark Weiss, J.D. They know what words mean, because the law can often turn on the meaning or phrasing of a law, as the examples of RICO definitions by several attorneys at the top of this article illustrate in abusing emails for the purpose of defrauding or other illicit purposes.

MHARR said last month that September 2023 data: “indicate that HUD Code manufacturers produced 7,955 new homes” while October statistics: “statistics indicate that HUD Code manufacturers produced 8,393 new homes.” Sequentially, that is “up.” Perhaps that is what MHI meant by “production is up” in their email? But then note that MHARR factually noted observed: “October 2023, a 3.4% decrease from the 8,649 new HUD Code homes produced in October 2022.” (Emphasis added by MHProNews).

Hold those thoughts on production and shipments, and let’s press on to other elements in MHI’s 12.6.2023 email.

To grasp the significance of their email’s pitch for Clayton and CrossMods® consider, the following facts.

Over a dozen years before those CrossMods® homes were placed in Atlanta, GA, HUD produced a federally commissioned report on manufactured homes that were installed in several urban areas in different parts of the United States. The photo below is not of a so-called CrossMod® home, rather it is a typical manufactured home, what MHARR sometimes refers to in the post-CrossMod® era as a ‘mainstream’ manufactured home. Stop and think from a perspective of maximizing manufactured housing sales, which are so tepid and apparently embarrassing that MHI didn’t dare state the facts clearly in their 12.6.2023 email. Which is more important? To get an MHI-dominating Clayton made – and far costlier – CrossMod home placed in Atlanta? Or is it more important to get potentially hundreds of thousands of manufactured homes, single section (like the one below) or multiple section ones placed in urban areas across the U.S.?


Note: to expand this image below to a larger or full size, see the instructions

below the graphic below or click the image and follow the prompts.

Several of the illustrations shown in this report can be opened in many browsers to reveal a larger size. To open this picture, click the image once. When the window opens, click it again to reveal the larger size photo.

Isn’t the answer obvious?

CrossMods®  sales are so low that their advocates won’t give the total number of CrossMods®  sold since the program launched some 6 years ago. There are indications that the total number of CrossMods®  sold in that time is perhaps 100 (+/-) throughout the country. To put it into perspective, during a time when some 600,000 HUD Code manufactured homes were sold nationally, maybe 100 CrossMod® homes were sold. That’s a terrible outcome, and clearly contradicts what MHI claimed on the subject when they launched and promoted it. Indeed, MHI itself admitted that the program was failing in critical ways in a letter obtained and published by MHProNews, see the report linked below.




As a senior level executive for an MHI member firm told MHProNews, “I see no traction in the program.”


This quote from an MHI insider was uploaded on 4.30.2020. As is so often the case, it has stood the test of time.


It doesn’t matter how many times MHI CEO Lesli Gooch, Ph.D., or MHI President Mark Bowersox, may sit in front of a screen for a photo op or video which has the image of a CrossMods® on it. Such attempts at illusion don’t change the reality that the CrossMods® program is failing. MHProNews predicted trouble years ago in our “Trojan Horse” report. Yet, MHI corporate and senior staff leaders keep pushing it. Why?

Perhaps one of the strongest critiques of CrossMods® didn’t come from MHARR, MHProNews, or MHLivingNews. It came from the Modular Home Builders Association and their executive director Tom Hardiman.




The reports that we published on CrossMods® over the years have stood the test of time, as has much of the critique by Hardiman or MHARR. But MHI keeps pushing it. Look again at some pull quotes from what MHI said. Look too at the video they linked, which MHProNews in their email above, linked to their YouTube page. As of 5:08 AM on 12.8.2023, there are only 276 views on that Clayton-CrossMod® video.



The sinister nature of paltering is that every word of a subject may be true, and yet it can still be misleading. Paltering is a notion that every manufactured home professional, indeed every American, should become completely aware of, because paltering – per Harvard – is becoming all too common in politics, business, and advocacy. While MHI is claiming in their 12.6.2023 email to be working to ‘stop’ the energy standards rule from going into effect, Clayton Homes in the video above is all but embracing that rule. Neither MHI’s email, nor Clayton’s video says what MHARR did in the exclusive Q&A with Danny Ghorbani and MHProNews on the topic. As a reminder, MHProNews exposed the fact that documents we obtained reveal that MHI negotiated with DOE to get the rule into effect! Would MHI have bothered to sue DOE absent MHARR and MHProNews’ consistent pushback and exposure of the issues?


“A More Costly “Re-Boot” of “Fatally-Flawed” “Fundamentally-Tainted, Sham DOE “Negotiated Rulemaking Process” – Smoking Gun Documents, MHARR, MHI, Manufactured Housing, You; plus MHMarkets Facts+Analysis

Crow Time? Manufactured Housing Institute (MHI), Texas Manufactured Housing Association (TMHA) File Suit v DOE’s MH Energy Rule Regs, Case No. 23-cv-00174 – Docs, MHARR Factor, Analysis


When MHI is celebrating that a piece of legislation has moved out of a House committee, they fail to tell their readers that MHI proposed bills like this years ago that went nowhere (see report linked below). With a Democratic Senate a narrowly Republican House, and Democrat Joe Biden in the White House ready to veto it if a miracle occurred in Congress, is this bill that MHI is cheerleading likely to pass? Hardly. Once again, it is a claim that may be technically true in some respects, but it is a partial truth that in essence is being used in a deceptive and misleading manner.




By essentially fostering, allowing, or creating problems for the manufactured housing industry that they may later hope to solve, regulatory barriers become the de facto ally of consolidators at MHI. That is part of the nature of sabotaging monopolies. Who said? Among others, James A. “Jim” Schmitz Jr., a senior economic researcher for the Minneapolis Federal Reserve.

“It took me years and years to unravel the sabotage [of manufactured homes and factory-built housing] I have found,” said Schmitz.

‘Affordable Homes for Low Income Must Produce in Factory,’ ‘Years to Unravel Sabotage,’ Grad Students Interest in Manufactured Housing, Factory-Home Solutions; plus Sunday Weekly Headlines Recap


Schmitz points to sabotage by those outside of the manufactured housing industry which in turn benefits those inside the manufactured housing industry that are steadily consolidating the business.




By grasping and being aware of the treacherous nature of paltering, posturing, projecting, and other devious methods of misleading, some of the “deception and misdirection” tactics deployed by various elements inside MHI are better understood. Once they are better understood, those traps and pitfalls can be more readily avoided.

Let’s go back to how MHI and various leaders in that organization have talked up CrossMods® despite their years of ever-more apparent market failures.  “Regulatory Barriers…” – the HUD report mentioned above about manufactured homes in urban settings, also featured this image. That’s a HUD Code manufactured home built years before CrossMods® and the MHI cheerleading for placement of 2 CrossMods® in Atlanta. Which is more important? To get access for ALL manufactured homes to be placed in urban infill opportunities? Or to only get a limited few CrossMods® available for that privilege? Which is more important? To get the less expensive manufactured homes placed where zoning barriers make it more difficult for HUD Code homes, or to get the most expensive manufactured homes placed?


Note: to expand this image below to a larger or full size, see the instructions

below the graphic below or click the image and follow the prompts.

Several of the illustrations shown in this report can be opened in many browsers to reveal a larger size. To open this picture, click the image once. When the window opens, click it again to reveal the larger size photo.


Their latest email above is once more an example of how arguably devious the minds of MHI leaders apparently can be.

But to put it in still brighter contrast, consider what Cavco Industries William Bill Boor, now the chairman, but then the Vice Chairman of MHI, told Congress last summer.

“HUD must strengthen preemption enforcement…and provide…transparent guidelines for compliance. Further, HUD must respond promptly and definitively whenever localities violate” enhanced preemption under the Manufactured Housing Improvement Act of 2000. That sounds almost like Mark Weiss at MHARR.




But there is a pragmatic problem with that argument by Boor, or by many others at MHI. It is this. MHARR offered to litigate this issue some 4 years ago. If MHI actually wants preemption robustly enforced, then why didn’t MHI jump at that opportunity? Why didn’t any MHI state association affiliates jump at that chance to join forces with MHARR to get ALL HUD Code manufactured homes – using enhanced federal preemption – available for placement in urban areas like Atlanta?


2IncredibleShrinkingZoningProblemManufacturedHousingAssocRegulatoryReformIssuesPerspectivesSept2019 MHARR reached out to MHI affiliated state associations in an offer to work with them to identify and advance a case to press the Manufactured Housing Improvement Act of 2000 (MHIA or ‘2000 reform law’) in 2019. Now approaching 4 years later, there has been no similar effort by MHI. Why not? Given that MHI-TMHA has filed suit in the DOE matter, it should immediately call into question why they have not done so on the other issues that have limited manufactured housing for the bulk of the 21st century.


MHI can’t have it both ways. They can’t, as Boor expressed, claim to be for enhanced preemption enforcement while at the same time slyly ignoring opportunities to force HUD’s hand, and/or that of local jurisdictions.  MHI can’t claim to want to help lower income blacks and others get their chance for a part of the American Dream, and when an opportunity to actually act upon a real case of helping an actual black family that wanted a manufactured home stifle that chance by ignoring it and sharing platitudes instead of concrete action.




This email is once again an apparent example of refined deception by MHI leaders at work. Nor will MHI likely challenge it.

Indeed, it is odd that MHI uses their legal tools to keep at bay the critics of their organization, instead of deploying those attorneys to litigate the regulatory issues that have kept the industry stuck in low gear throughout the 21st century.

Note: to expand this image below to a larger or full size, see the instructions

below the graphic below or click the image and follow the prompts.

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.


With such thoughts in mind, look again – or for the first time – at the reports linked herein, including those that follow below.


Dip Drops but U.S. Manufactured Home Production Decline Hits One Year-Dec 2023 Manufactured Housing Association for Regulatory Reform Report-Oct 2023 Production-Shipments; plus MHVille Markets

Nearly $2 Billion for Startups BUT…Crunchbase-AI–Why Factory-Building Newbies Struggle During Affordable Housing Crisis–Good, Bad, or Meh for Manufactured Housing? Plus, MHVille Markets Update

Kevin O’Leary-Zillow-JP Morgan-Shrinking Economies-2024 Outlooks as Viewed by Investors Experts and Reports-What it Could Mean for Manufactured Housing Facts-Analysis; plus MHVille Markets


Barron’s Says Suit Risks Warren Buffett ‘Good Guy Image’-Greg Abel, Class Action, Antitrust Suits vs Berkshire Brand Raises Fresh Concerns Over Clayton Homes Parent Berkshire Hathaway Tactics


This isn’t garden variety ineptitude or ordinary corruption that appears to be at work at MHI. Rather, this seems to be a deft series of coldly calculated choices made by MHI leaders for a very specific intent, which is to benefit the insiders while slowly harming smaller business, much of the affordable home buying public, investors, taxpayers, and other stakeholders. More specifically, this pattern benefits consolidators. See the growing pile of evidence in the deep dive report linked below.  Keep in mind that MHI leaders and their attorneys would not respond to that evidence, nor others published on MHProNews/MHLivingNews. Nor have MHI leaders responded to the opportunity to publicly debate their performance at an upcoming industry trade event. If MHI corporate and senior staff leaders are so darn sure of themselves, if they are so pure and good, then why won’t they be publicly accountable in front of an audience of manufactured home industry professionals? Perhaps there is too much evidence for them to refute? Perhaps they don’t want to be lynched by those they have harmed at the end of a public debate?




If it is their personal security that MHI leaders or attorneys are worried about, we’ll debate them online instead.  Let it be pre-announced to the media, livestreamed, and moderated by an independent third party. What could they say to that?

As independent retailer Bob Crawford aptly noted, ‘If We Keep Doing What We’ve Been Doing We Will Keep Getting What We Got!’ See what Crawford suggested at that linked report.  As a suggestion to those who truly want to wrap their minds around why manufactured housing is underperforming during an affordable housing crisis, read this article – or any of those linked/crosslinked – twice. The first time, get the quick impressions, the second time, check every fact and insights carefully. The picture will be clear once the details are grasped. That’s why we have advocated for litigation for years. The start of such needed litigation appears to be underway. More is necessary. Remember, odds are excellent you read that here first.  ##


Ponder how this “never give up the con” quote applies to the mendacity and paltering that has obviously occurred in manufactured housing in the Berkshire era.

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below the graphic below or click the image and follow the prompts.

Ironically, Skyline Champion’s own investor pitch-deck provides ample evidence for manufactured housing industry underperformance. That same pitch-deck further provides evidence that Mergers and Acquisitions are a key part of their business model. What is there in such revelations that Birch and Williams miss? Bear in mind, that they are mere stand-ins who voluntarily raised their hands in defense of Berkshire and MHI firms like Skyline Champion. Notice: Several of the illustrations shown in this report can be opened in many browsers to reveal a larger size. To open this picture, click the image once. When the window opens, click it again to reveal the larger size photo. Use your browsers back key to return to the article.


Part III – is our Daily Business News on MHProNews stock market recap which features our business-daily at-a-glance update of over 2 dozen manufactured housing industry stocks.

This segment of the Daily Business News on MHProNews is the recap of yesterday evening’s market report, so that investors can see at glance the type of topics may have influenced other investors. Thus, our format includes our signature left (CNN Business) and right (Newsmax) ‘market moving’ headlines.

The macro market move graphics below provide context and comparisons for those invested in or tracking manufactured housing connected equities. Meaning, you can see ‘at a glance’ how manufactured housing connected firms do compared to other segments of the broader equities market.

In minutes a day readers can get a good sense of significant or major events while keeping up with the trends that are impacting manufactured housing connected investing.


Reminder: several of the graphics on MHProNews can be opened into a larger size. For instance: click the image and follow the prompts in your browser or device to OPEN In a New Window. Then, in several browsers/devices you can click the image and increase the size. Use the ‘x out’ (close window) escape or back key to return.


Headlines from left-of-center CNN Business – from the morning of 12.7.2023

  • CPSC issues several warnings for tiny magnetic balls after seven deaths
  • The Cameo website on a laptop computer arranged in Dobbs Ferry, New York, U.S., on Saturday, Feb. 13, 2021. Cameo, an app connecting customers to celebrities paid to record personalized messages, is in discussions to raise funds at a valuation of about $1 billion, according to people familiar with the matter. Photographer: Tiffany Hagler-Geard/Bloomberg via Getty Images
  • Russian propagandists exploited celebrity Cameo videos to spread disinformation, Microsoft says
  • The Facebook logo is seen on a phone in this photo illustration in Washington, DC, on July 10, 2019.
  • Meta rolls out encrypted messaging by default for Facebook and Messenger
  • University of Pennsylvania President Liz Magill reads her opening statement during a hearing of the House Committee on Education on Capitol Hill on December 5 in Washington, DC.
  • University of Pennsylvania board of trustees holds emergency meeting after president Liz Magill’s disastrous testimony
  • American actor James Stewart (1908 – 1997) as Jefferson Smith in ‘Mr Smith Goes To Washington’, directed by Frank Capra, 1939.
  • A new bedtime story voiced by Jimmy Stewart just in time for Christmas, 26 years after his death
  • A large X logo is visible on the roof of X headquarters on July 31, 2023 in San Francisco, California. Just over 48 hours after a large X logo with bright pulsating lights was installed on the roof of X headquarters in San Francisco, workers dismantled the structure on Monday morning. The city of San Francisco opened a complaint and launched an investigation into the structure and residents in neighboring buildings complained of the sign’s bright strobe lights.
  • Former Twitter head of information security claims he was fired after raising concerns about cost cuts at Elon Musk’s company
  • The Adani Group’s solar power panel assembly plant in Mundra, India, on Oct. 27, 2022.
  • India’s urban population is exploding. That could have huge consequences for the planet
  • Left: Taylor Sheridan; right: Cole Hauser.
  • ‘Yellowstone’ creator and actor battle over coffee company’s logo
  • A for sale sign is posted outside a home in the Angelino Heights historical neighborhood of Los Angeles, on Oct. 19, 2023.
  • Mortgage rates drop to lowest levels since August
  • U.S. Sen. Ron Wyden (D-OR) participates in a Senate Finance Committee hearing with Health and Human Services (HHS) Secretary Xavier Becerra on March 22, 2023 in Washington, DC. Becerra testified on the FY2024 budget request for the Department of Health and Human Services.
  • Foreign governments may be spying on your smartphone notifications, senator says
  • Elon Musk demands Bob Iger ‘be fired’ after Disney pulled ads from X
  • America is becoming a country of YIMBYs
  • ‘Oppenheimer’ to be released in Japan after delay following ‘Barbenheimer’ controversy
  • Why the US economy has powered ahead of other rich nations
  • What to expect from Friday’s jobs report
  • Recycling palm trees could cut methane emissions and create a green alternative to plywood
  • The US shoplifting scourge is a lot of hype with little evidence
  • Retail investors are sitting out the stock resurgence
  • Trump and his allies are threatening retribution against the press. Their menacing words should not be ignored
  • From the Boy Scouts to the Catholic Church, an upcoming Supreme Court ruling may mean some victims won’t see their day in court
  • Hong Kong wants more business with Saudi Arabia. Here’s why
  • Germany’s stock market just hit a new record high despite a faltering economy. What gives?
  • China’s real estate crisis is coming for its massive shadow banks


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