Manufactured Housing Institute ‘Urges HUD Address Manufactured Housing in Affirmatively Furthering Fair Housing Rule’–Unpacked Evidence-Views, Tips, MHVille Insights on Manufactured Home Reality


“MHI Urges HUD to Address Manufactured Housing in its Affirmatively Furthering Fair Housing Rule” said the Manufactured Housing Institute (MHI) in its Wednesday, early evening (circa 5:30 PM ET) April 26, 2023 email to members, affiliates, and other readers. There was no attached copy of those MHI remarks, as their national association rival Manufactured Housing Association for Regulatory Reform (MHARR) sent out last week with their news release on 4.24.2023 to industry readers and other affordable housing advocates. One might wonder what, if anything, MHI ‘lifted’ from MHARR remarks in crafting their own comments to the U.S. Department of Housing and Urban Development (HUD)? MHARR’s remarks are posted here on their website and their comments are found linked here on MHProNews along with commentary and analysis. Additionally, more on that is found on the Masthead with a fact and evidence-backed editorial that follows an exclusive Q&A on that topic.

  • Part I of today’s report will be the complete remarks MHI provided to their readers.
  • Part II will be additional information, including more eye-opening facts and views on this potentially useful topic for manufactured housing industry expansion.

Part I

MHI Urges HUD to Address Manufactured Housing in its Affirmatively Furthering Fair Housing Rule

MHI submitted comments to assist HUD in the development and guidance for implementing and reinstating the Affirmatively Furthering Fair Housing (AFFH) rule. MHI expressed support for the proposed rule which seeks to reduce housing discrimination and to promote fair and affordable housing across the United States by reforming and restoring tools that can be used to hold local jurisdictions accountable in their land use planning and zoning actions.  ##

Part II – Additional Facts with More Information, Tips, Analysis and MH Expert Editorial Commentary

Five days after MHI’s emailed remarks, shown above, on 5.1.2023 at 8:46 AM ET, there are NO results on the MHI website for AFFH, the common abbreviation for HUD’s pending Affirmatively Furthering Fair Housing rule. A similar check of the MHI website for the full name spelled out – Affirmatively Furthering Fair Housing (AFFH) – used by MHI in their ‘release’ to members of the manufactured housing industry (a.k.a. “MHVille”) also turned up nothing on the same date at about the same time. Evidence for those facts are shown further below.

That begs the question. Why does MHI send out emails to members and followers on issues that they claim to want to see implemented, and then fail to post them on their own website?

By contrast, MHI has had an illustration for trademarked CrossMod® style manufactured home on their home page for years. A search yields 5 results. That count of 5 may be more than the total number of CrossMods financed by Freddie Mac since they announced the program some years ago. In fairness, Fannie Mae has supposedly financed more CrossMods, but the total sold may only be in the double digits out of the hundreds of thousands of HUD Code manufactured homes sold during that same timeframe.  While MHI and their leaders seems to avoid using hard numbers, MHI admitted in the latter part of 2022 that their CrossMods program has floundered. Nevertheless, MHI senior staff and their corporate bosses keep pushing on it despite years of arguably costly failures. Of course, MHProNews advised  readers that MHI insiders quietly admitted the program had “no traction” years ago. That reality appears to remain unchanged. The MHProNews projection that the program Could end up as a “Trojan Horse” for manufactured housing proved to be accurate.


This report was posted Feb 21, 2018. It predicted that the so-called ‘new class of homes’ could be a ‘Trojan Horse’ for manufactured housing. If one measures performance by new homes shipped, that concern has proven to be true. How could we know almost 2 years in advance where the industry might be today? Because we know the industry from the inside, not just as publishers – but as performance based professional service providers. The MHI plan – supported by firms such as Clayton Homes, Skyline Champion, Cavco Industries, Fannie Mae and Freddie Mac, was arguably flawed from the outset.

This paragraph may sound harsh at first, but it is meant to provoke serious thought. Facts and evidence matter. They are whatever they are, whether we like the facts or not. MHProNews and our MHLivingNews sister site have made the point several times that MHI’s corporate and senior staff leadership cannot possibly be as inept and incompetent as their performance could lead someone to believe. These are educated, seasoned professionals. That logically means that those leaders ought to be able to produce good, measurable results. To illustrate the facts involved in that statement, consider the following bullets. First the facts (A), then those facts will be followed by their implication and meaning (B).

  • 1) MHI leaders pivoted in the late 20th century and joined with MHARR in pushing for what became the Manufactured Housing Association for Regulatory Reform (MHARR).  MHI’s own document from a few years after its enactment – linked here (click to open image) – illustrates that point. Note this is occurred early in the Berkshire Hathaway era of modern manufactured housing.
  • 2) MHI leaders and MHARR both worked to get the Duty to Serve (DTS included in the Housing and Economic Recovery Act (HERA) of 2008. See this MHI document as evidence from former MHI vice president of communications, Bruce Savage, which clearly stated that both MHARR and the MHI trade organizations were working together on financing issues. That too is fairly early in the 2002-2003 start of the Berkshire era of manufactured housing. (Note: click those links in #1 and #2 to open the document or image.)
  • 3) In 2009, Tim Williams, president and CEO of Berkshire Hathaway owned 21st Mortgage Corporation – which supplies financing to non-Clayton Homes (a sister firm to 21st and also Berkshire owned company) owned locations, said in his letter linked here (click to open) that the industry should turn to Congress and get them to push Fannie Mae and Freddie Mac to providing chattel financing for HUD Code manufactured homes. Some 14 years later, where is that chattel or home only lending? Tick tock, tick tock, time has moved on and there is no measurable results. Hmmm…
  • 4) More specifically, here is what 21st’s Williams said on January 30, 2009 about getting government support for more manufactured housing single family “home only,” personal property or “chattel” lending. “Finally, I urge you to contact your U.S. Congressman and Senator to ask them to [1) demand FHA Immediately increase the maximum loan limit for manufactured homes [2] insist Fannie [Mae] and Freddie [Mac} immediately provide funding programs for home only and land/home manufactured homes.” Again, see an illustrated image of that letter linked here (click to open), that part of the letter quoted is near the end.
  •  5) MHI’s Lesli Gooch admitted that there is no progress on DTS, see Gooch’s remarks linked here (click to open).
  • 6) When the Obama-Biden Administration came into office, the Dodd-Frank Act followed. It should be recalled the Warren Buffett, chairman of Berkshire Hathaway publicly supported Obama’s election and re-election.
  • 7) With Dodd-Frank came regulations that MHI subsequently spent years and reportedly millions of dollars in ‘fighting’ to reform to make more lending on manufactured homes available. That effort was billed as the “Preserving Access to Manufactured Housing Act.”  21st’s Williams, who served as an MHI chairman and is still an MHI board member, told the industry via exclusive remarks made to this publication, that if the industry failed to get Preserving Access passed that “financing in our industry is doomed.” Sounds serious, right?  That was August 1, 2013. So, almost a decade later, with the Preserving Access to Manufactured Housing Act NEVER having been passed, manufactured housing is quite alive.
  • 8) Fast forward. An MHI insider told MHProNews that 21st’s Williams said during an MHI meeting that Williams was “happy” that the pilot projects by Fannie Mae and Freddie Mac did not go into effect. That was reported by MHProNews on November 5, 2020. Neither MHI, nor Williams, nor their attorneys have ever sent a request for clarification or denied the accuracy of that report.
  • 9) Jump ahead to August 25, 2022. The Masthead said that MHI’s planned bill on the DOE energy rule was bound to go nowhere. We cited the sources, evidence, and logic in support of that contention. It turned out that MHProNews (and this writer) proved to be correct.  But that begs the question. If someone (moi) without a Ph.D. in political science, such as Lesli Gooch, MHI’s CEO has, can accurately forecast why that MHI bill was doomed, why couldn’t Gooch and MHI’s leaders have seen that coming months in advance too?  Then, look at our recent report linked here on the DOE topic and MHI’s vs. MHARR’s behavior.
  • 10) Pages of such examples could be made, but let’s bring this part to a conclusion by noting that unlike MHI’s website, which has no mention of Affirmatively Furthering Fair Housing or AFFH, by contrast, MHLivingNews did a long form video interview that specifically referenced points quite similar to what MHARR did. Our article with video that is linked below was posted on 2018/10/20, over four years ago.

B) Given those 10 points of examples above on several of the current (and years of ongoing) topics illustrate, it should be apparent that MHI leadership seems to have a clear pattern. That pattern could be summed up like this.

  • 1) MHI takes a position on an issue which often may appear to be similar to what MHARR is saying on the same topic. Indeed, MHI is said to have filed their comments at times, or even filed a lawsuit, that may have been influenced by remarks previous made by MHARR without giving MHARR credit. Once the AFFH comments by MHI are obtained, the dates on both filings will be compared. Again, note that MHARR provided their comments, MHI did not. MHARR provides their remarks publicly on their website, MHI does not.
  • 2) MHI fails to get accomplished what they claim to want accomplish in anything like a reasonable length of time.
  • 2a) Think Manufactured Housing Improvement Act of 2000 (Kevin Clayton’s remarks on behalf of MHI are linked here). Over 22 years have elapsed.
  • 2b) The Duty to Serve (DTS) is not fully implemented, as Gooch admitted (see linked above). But 21st’s Williams, who a recent list on the MHI website says is still on MHI’s board, and Williams told a modest group of MHI members that he was “happy” that the industry has yet to get that implemented. Of course. After all, getting that implemented would likely have cost 21st some business. See what a Warren Buffett ally and author Bud Labitan said on financing the Buffett’s “moat” in manufactured housing, see the second segment of the Masthead report linked here.
  • 2c) MHI’s efforts on AFFH have obviously not progressed in either the Trump or the Biden era. See above.
  • 2d) The jury is still out on MHI and the DTS rule and related lawsuit. But suffice it to say that had MHARR not spotlighted and pressed the need for legal action, MHI may well have failed on this too.  Recall that MHProNews exclusively published the history of DTS, and MHI’s purportedly underhanded handling of the issue.
  • 2e) The MHARR White Paper made the case approaching a year ago that on issue after issue seemingly good sounding measures in Washington, D.C. fail to “reach the ground” – despite MHI’s cheerleading.
  • 3) Despite a questionable effort by an apparent MHI blogging ally, one George F. Allen, to spin the issue of industry promotion and education, the history of the industry (which Allen essentially admitted) is that MHI has long failed to do anything. Clear evidence of that was documented citing Kevin Clayton and others in the report linked below.

Warren Buffett’s Pledge to Kevin Clayton – ‘You Can Access Plenty of Capital’ for Projects – Quotes, Facts, Video, Transcript, and Implications for Manufactured Housing Industry

What MHI is good at doing is self-promotion. In that they and Allen have a bit in common.



C: That’s an array of facts and evidence that leads an objective thinker to the following possible conclusion.

  • 1) MHI is either terrible at getting their own claimed agenda into effect.
  • 2) MHI’s stated agenda is not actually what they are working for – which begs the question, what is their unstated agenda?
  • 3) This is fairly easy at this point to demonstrate, because several of MHI’s publicly traded corporate leaders produce remarks and investor relations pitches that tell us what that agenda is. It is industry consolidation. Former MHI chairman, Nathan Smith, and his company – Flagship Communities – put it like this.

Notice: the graphic below can be expanded to a larger size.

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

Several publicly traded firms are making similar statements, but this one happens to have a partner and co-founder a prior MHI chairman, Nathan Smith.

Speaking of obvious evidence of how corrupt, crony capitalist, and circular promoting MHI and their insider brands are, is this unchallenged report linked below.



Nathan Smith (Flagship/SSK/MHI board), MHI chairman and CEO, and their attorneys were asked to respond. Days later? Silence.

‘Deception and Misdirection’-MHI Proxy Response to Concerns About “Awards” to BBB D- rated Flagship Communities – ‘Facts are Stubborn Things’ Commentary; plus Sunday Weekly MHVille Headline Recap

MHProNews began some years ago to document evidence of manufactured housing underperformance. Outside the industry metrics were used. Inside the industry metrics were also examined. See examples shown and linked below.

Notice: the graphic below can be expanded to a larger 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 can be clicked to expand. Click the image and follow the prompts. For example. Click the image and you may see an option to open the image in a new window. Click that option. Then, in the new window click the image to expand it to a larger or full size. To return to this page, use your back key, escape or follow the prompts.


MHProNews painstakingly documented, as has MHLivingNews, the factual realities of our industry.


New U.S. Conventional Housing Nears 450K Average as Sales Up in March 2023 vs Manufactured Housing’s Reported Dive – Added Facts, Opportunities, Obstacles, MHMedia Views – plus MHVille Market Update


We’ve examined and highlighted third-party research that may total into the thousands of pages. That research demonstrates directly and indirectly how much better manufactured housing could be performing vs. how poorly it is performing by historical standards as measured by actual homes built, sold and shipped. By contrast, what does MHI do? They give a research report that provides their latest excuses for why the industry is underperforming at present.


Notice: the graphic below can be expanded to a larger size.

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Compare the data from 4.5.2023 MHI PowerPoint these two slides are from to the facts, analysis and expert commentary found on the MHProNews Masthead dated 4.4.2023. 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.

Manufactured Housing April Updates for all 50 States for February 2023 Troubling Facts Paired with ‘Weasel Words’ by Manufactured Home Industry ‘Leaders’ – Data, Examples, Viewpoints, and Analysis


MHI leaders can’t escape their own words. Nor can MHVillage’s MHInsider,, “Frank and Dave” or slippery MHI ally George Allen show any consistent evidence that they are trying to hold the industry’s leadership accountable. To praise and/or promote the industry’s MHI leadership in the face of this evidence is as vexing as MHI’s behavior is. Following the money trail sheds light on why this pattern appears to be so.

‘The Rules Are Simple. They Lie to Us, They Know We Know They Are Lying;’ MHVillage/MHInsider Darren Krolewski Unveils Sobering Claim – ‘How to Waste Good Money on Marketing’ – plus MHVille Stock$


The rules are simple. They lie, palter, posture, and attempt to deceive and mislead the industry. Some in the industry are either aware, and may favor what MHI does (because it benefits them) or remain silent for a variety of reasons. But a longtime MHI insider told MHProNews that the industry will never recover in our lifetimes. Unless, of course, this troubling pattern is changed.


Lawyer Tip$, LCI, PATK, Scholar=Manufactured Housing Institute Insider Says Manufactured Home Industry Sales ‘Will Never Recover to Prior Levels In Our Lifetime;’ plus MHVille Stocks Update


The industry’s honest professionals ought to carefully review the report linked below. It has a comical angle, but it also has a very serious side too.




This is the special report promised last week. A follow up to this is pending. Insights more manufactured home community focused is just ahead. But so are other topics, along with our industry leading coverage of other issues that impact our underperforming profession.

Notice: the graphic below can be expanded to a larger size.

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

HUD-Affirmatively Furthering Fair Housing Rule-ManufacturedHousingInstituteMHI2023-05-01_08-54-24-MHProNewsFactCheckAnalysisCommentary
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.

ManufacturedHousingInstituteLOGO-MHI-LOGO-MHIwebsiteScreenCaptureAFFH-Affirmatively Furthering Fair Housing rule.2023-05-01_08-47-46-MHProNewsFactCheck

In conclusion, the images above are among several such fact-checks by MHProNews/MHLivingNews that stand as reminders of MHI’s apparent head fakes. When MHI “urges” HUD, the history of the trade group in the 21st century is problematic in the Berkshire Hathaway era.  See the linked reports to learn more. To see how an authentic trade group for producers operates – and by inference, why the industry should create an equally authentic post-production trade group.  It is part of the solution to the problems identified within. The profits that and related tips could bring if properly implemented are enormous. ##




‘Deception and Misdirection’-MHI Proxy Response to Concerns About “Awards” to BBB D- rated Flagship Communities – ‘Facts are Stubborn Things’ Commentary; plus Sunday Weekly MHVille Headline Recap



‘Production at Lowest Levels in a Decade’ but 2023 Outlook ‘Optimistic for Texas Manufactured Housing Industry,’ says TRERC – Supply Chain, Finance, Report, Analysis; plus MHVille Stocks Update

‘Trapped’ – NBC Spotlights Fannie Mae-Freddie Mac-Fed Roles in ‘Making Mobile Homes Less Affordable’ Fueling ‘Acquisition Spree’ as ‘New MHC Owners Hike Resident Costs;’ plus MHVille Markets Update

Manufactured Housing Institute Federated States ‘News’ Fails to Mention Sharp Manufactured Home Production Drop–Posturing, Head Fakes, Gaslighting Concerns Explored; plus MHVille Stock Updates

Trade media can and should be a ‘cheer leader’ when it is appropriate to do so. But authentic trade media also holds the powers that be to account. Who says? The American Press Institute.
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Again, our thanks to free email subscribers and all readers like you, as well as our tipsters/sources, sponsors and God for making and keeping us the runaway number one source for authentic “News through the lens of manufactured homes and factory-built housing” © where “We Provide, You Decide.” © ## (Affordable housing, manufactured homes, reports, fact-checks, analysis, and commentary. Third-party images or content are provided under fair use guidelines for media.) (See Related Reports, further below. Text/image boxes often are hot-linked to other reports that can be access by clicking on them.)

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.

By L.A. “Tony” Kovach – for

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

This article reflects the LLC’s and/or the writer’s position, and may or may not reflect the views of sponsors or supporters.

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Related References:

The text/image boxes below are linked to other reports, which can be accessed by clicking on them.’

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Manufactured Housing’s Next BIG Regulatory Battle That MHARR’s Spotlighted and Which MHI Conveniently Ignored in Recent ‘Manufactured Housing Institute News;’ plus Sunday Weekly Headlines Recap




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