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August 2023 Production Data – Manufactured Housing Institute (MHI) Leaders Should Embrace Responsibility for Continuing Manufactured Home Production Decline – Consolidators Fueled Crisis?! 

August2023ProductionDataManufacturedHousingInstituteMHILeadersShouldEmbraceResponsibilityContinuingManufacturedHomeProductionDeclineConsolidatorsFueledCrisisMastMHProNews

Per Grammarist, “A day late and a dollar short is another way to say too little too late. When a person is a day late and a dollar short, he has not only missed an opportunity due to tardiness, but also because he has not put forth enough effort.” When examining contemporary MHVille landscape connected facts like the new manufactured housing production data found in Part I below, the idiom of “a day late and a dollar short” arguably seems to fit the Manufactured Housing Institute (MHI) on a range of issues through most of the 21st century. Let’s consider a few examples before diving into the latest production data collected on behalf of the U.S. Department of Housing and Urban Development (HUD).

  • There are far fewer new manufactured homes built today than there were in 2000, even though the U.S. population has grown significantly and there is a widely acknowledged need for affordable housing.
  • There are fewer land lease manufactured home communities today than there were in 2000.
  • There are thousands of fewer manufactured home independent street retailers today than there were in 2000 too.
  • When the ‘razzle dazzle‘ of self-praise, photo and video ops with public officials, and ‘echo chamber’ tactics are stripped away and people look at the hard data, the picture that emerges about MHI performance as measured by hard data is sobering and sad for proponents of affordable manufactured homes. More on that in Part II of this column, which will examine the notion of this being a consolidator fueled crisis for the manufactured housing industry.

Next up, in Part I of this column is the report from the Manufactured Housing Association for Regulatory Reform (MHARR) with the following information on the latest production and top states for manufactured home shipments.

 

Part I

Severe Manufactured Home Production Decline Continues in August 2023

Washington, D.C., October 5, 2023 – The Manufactured Housing Association for Regulatory Reform (MHARR) reports that according to official statistics compiled on behalf of the U.S. Department of Housing and Urban Development (HUD), HUD Code manufactured housing industry year-over-year production declined again in August 2023. Just-released statistics indicate that HUD Code manufacturers produced 8,670 new homes in August 2023, a 19.1% decrease from the 10,722 new HUD Code homes produced in August 2022. Cumulative production for 2023 is now 58,692 homes, a 27% decrease from the 80,431 homes produced over the same period during 2022.

A further analysis of the official industry statistics shows that the top ten shipment states from January 2023 — with monthly, cumulative, current year (2023) and prior year (2022) shipments per category as indicated — are:

October2023TopTenManufacturedHousingShipmentStatesPerManufacturedHousingAssociationForRegulatoryReformMHARR-LOGO-MHProNews

 

The statistics for August 2023 produce one change from last month, moving Alabama into 3rd place.

In the midst of an ongoing affordable housing crisis, with housing costs reaching or nearing all-time highs, inherently affordable manufactured housing continues to significantly underperform, with production levels for 2023 far below the industry’s potential and even the diminished annual production averages of the past decade-plus. As MHARR has explained and documented, this decline continues to be driven by key failures within the industry’s post-production sector including, most significantly, discriminatory zoning exclusion (tolerated by HUD) and the stubborn refusal of Fannie Mae and Freddie Mac to securitize chattel loans for nearly 80% of the industry’s most affordable mainstream manufactured homes. Unless and until someone within the industry can fully explain any and all other possible reasons for this decline, which has left the industry in its current downward spiral, the Manufactured Housing Institute, as the only national association which collects representation dues from the post-production sector of the industry, has a duty and obligation to press HUD as well as Fannie Mae and Freddie Mac to fully comply with the relevant existing laws (i.e., the 2000 reform law and the Duty to Serve law) going forward.

  The Manufactured Housing Association for Regulatory Reform is a Washington, D.C.- based national trade association representing the views and interests of independent producers of federally-regulated manufactured housing. 

— 30 —

 

Part II – Additional Information with More Masthead Editorial Facts and Analysis from MHProNews

On 10.4.2023 Bing’s AI Chat function was asked the following by MHProNews:

> “What is the estimated total of all manufactured home street retailer in the United States?”

“I’m sorry, but I couldn’t find a direct answer to your question.” …

MHProNews also asked Bing’s AI 💬 Chat this: >> “About how many manufactured home street retailers have been lost in the U.S. since 2000?”

“I’m sorry, but I couldn’t find a direct answer to your question.” …

> “What, if anything, has the Manufactured Housing Institute (MHI) said about the impact on street retailers and communities following the letter from Tim Williams, President and CEO of Berkshire Hathaway owned 21st Mortgage Corporation in 2009 that cut off lending to independent retailers who didn’t sell Clayton Homes or 21st to repossessions?”

I’m sorry, but I couldn’t find any direct information on what the Manufactured Housing Institute (MHI) has said about the impact on street retailers and communities following the letter from Tim Williams, President and CEO of Berkshire Hathaway owned 21st Mortgage Corporation in 2009 that cut off lending to independent retailers who didn’t sell Clayton Homes or 21st to repossessions.

However, I found an article on Manufactured Home Pro News that mentions Kevin Clayton’s testimony to Congress. According to the article, Kevin Clayton, President and CEO of Clayton Homes, entered testimony into the federal record on behalf of MHI 1. The article also mentions that the testimony was obtained thanks to staff working for Democratic lawmakers in Washington, D.C.

I hope this information helps!

Learn more:

  1. manufacturedhomepronews.com 2. manufacturedhomepronews.com 3. manufacturedhomepronews.com 4. manufacturedhomepronews.com 5. manufacturedhomelivingnews.com 6. manufacturedhomepronews.com 7. manufacturedhomepronews.com 8. lincolninst.edu 9. cnbc.com 10. manufacturedhomepronews.com 11. docs.house.gov

> “What sources in manufactured housing have alleged that the Williams/21st letter was an apparent violation of antitrust laws?”

I found an article on Manufactured Home Pro News that mentions a Prima Facie Cases Against Manufactured Housing Institute 1. The article alleges that the Manufactured Housing Institute (MHI)Richard A. ‘Dick’ JennisonTim Williams21st MortgageKevin ClaytonTom Hodges – Clayton Homes, and others have engaged in wrongdoing within the manufactured housing industry that directly or indirectly impacts almost everyone in the United States because of the vital nature of affordable housing. The article also mentions that the letter from Tim Williams, President and CEO of Berkshire Hathaway owned 21st Mortgage Corporation in 2009 that cut off lending to independent retailers who didn’t sell Clayton Homes or 21st to repossessions was an apparent violation of antitrust laws 1.

I hope this information helps!

Learn more:

  1. manufacturedhomepronews.com 2. equitablegrowth.org 3. ftc.gov 4. manufacturedhomepronews.com 5. manufacturedhomelivingnews.com 6. manufacturedhomepronews.com 7. manufacturedhomepronews.com 8. lincolninst.edu 9. cnbc.com 10. manufacturedhomepronews.com 11. docs.house.gov 12. forbes.com 13. mhvillage.com 14. stacker.com 15. docs.house.gov

 

Note that some of the links above are not on point with the question, including, but not limited to the link on MHVillage. That link on MHVillage provides some apparently inaccurate information, which was previously explored and debunked as warranted based on evidence such as what the Lincoln Institute’s CEO George McCarthy said, based upon federal data.

Note too MHVillage and MHInsider were part of the deal made by Equity LifeStyle Properties (ELS) to buy Datacomp. ELS and Datacomp have recently been hit with a class action antitrust suit. That suit noted the ties between several of the defendants and the Manufactured Housing Institute (MHI).

> “What allegations have been made against MHI CEO Lesli McCollum Gooch, Ph.D.?”

I found several articles on Manufactured Home Pro News that mention allegations against Lesli McCollum Gooch, Ph.D., the CEO of the Manufactured Housing Institute (MHI) 123. According to these articles, there have been allegations of conflicts of interest and apparent violations of antitrust laws by MHI and its leadership. The articles also mention that there are documents that suggest that Gooch was working for outside interests in the housing field while working full-time for MHI, which raises questions about the effectiveness and transparency of MHI 13.

I hope this information helps!

Learn more:

  1. manufacturedhomepronews.com2. manufacturedhomepronews.com3. manufacturedhomepronews.com4. manufacturedhomepronews.com5. americanbanker.com6. opensecrets.org7. manufacturedhomelivingnews.com8. manufacturedhomepronews.com

> “What has Samuel Strommen with Knudson Law alleged with respect to the Manufactured Housing Institute?”

According to an article on Manufactured Home Pro News, Samuel Strommen, an Associate Attorney with Goodsell Oviatt Law Firm in Rapid City, South Dakota, authored a research paper entitled “The Monopolization of the American Manufactured Home Industry and the Formation of REITs: a Rube Goldberg Machine of Human Suffering” 1The paper exposes a number of antitrust violations in the form of the increasing monopolization of the manufacturing, financing, and the increasingly consolidating landlords, and calls for reforms within this industry 1The paper was first published on ManufacturedHomeProNews.com on February 1, 2021 1.

I hope this information helps!

Learn more:

  1. manufacturedhomepronews.com 2. einpresswire.com 3. tampafp.com 4. manufacturedhomepronews.com 5. einnews.com 6. manufacturedhomepronews.com 7. manufacturedhomelivingnews.com 8. manufacturedhomepronews.com 9. manufacturedhomepronews.com 10. manufacturedhomepronews.com 11. bing.com 12. manufacturedhomepronews.com 13. manufacturedhomelivingnews.com 14. manufacturedhomepronews.com 15. einnews.com 16. manufacturedhomepronews.com

> “What has James Schmitz Jr and his Minneapolis Federal Reserve research colleagues alleged about the low production levels in manufactured housing?”

According to a report by the Federal Reserve Bank of Minneapolis, monopolies inflict great harm on low- and middle-income Americans 1. One of the ways they harm them is by sabotaging low-cost products that are substitutes for the monopoly products. The report argues that the U.S. housing crisis, legal crisis, and oral health crisis facing the low- and middle-income Americans are, in large part, the result of monopolies destroying low-cost alternatives in these industries that the poor would purchase 1.

James A. Schmitz Jr., a Senior Research Economist at the Federal Reserve Bank of Minneapolis, has authored several research papers on the subject of monopolies in the manufactured housing industry 123In his paper titled “Solving the Housing Crisis will Require Fighting Monopolies in Construction,” Schmitz argues that monopolies in construction are a major cause of the housing crisis in America 3He suggests that affordable homes for low-income people must be produced in factories to reduce costs and increase production levels 4.

I hope this information helps!

Learn more:

  1. minneapolisfed.org2. econpapers.repec.org3. minneapolisfed.org4. manufacturedhomepronews.com5. manufacturedhomepronews.com6. doi.org

> “What did law professor Daniel R. Mandelker say about the need for manufactured housing legal and lobbying advocacy?”

According to an article on Manufactured Home Pro News, Daniel R. Mandelker, a law professor, has called for an organization that can provide litigation and legislative support to help manufactured housing advocates with zoning reform 1Mandelker’s research paper titled “Zoning Barriers to Manufactured Housing” argues that judicial control of zoning barriers to manufactured housing is unsatisfactory and requires statutory change 2The paper also suggests that courts accept unequal treatment that applies restrictive zoning only to manufactured housing, though some statutes prohibit discrimination 2.

I hope this information helps!

Learn more:

  1. manufacturedhomepronews.com2. papers.ssrn.com3. intranet.law.wustl.edu4. law.wustl.edu

> “At least twice in the last 6 years, the Manufactured Housing Institute (MHI) said that the industry had “momentum,” but what in fact followed that MHI remark with respect to manufactured housing production levels?”

According to an article on Manufactured Home Pro News, the Manufactured Housing Association for Regulatory Reform (MHARR) has published a research White Paper that exposes a decades-long pattern of public relations exploitation by the supposed representative of all segments of the manufactured housing industry of laws and government benefit programs which purportedly include federally-regulated manufactured housing but, in fact, fail to achieve or deliver results on the ground for either the industry or consumers 1.

The latest information about HUD Code manufactured home production from the Manufactured Housing Association for Regulatory Reform (MHARR) revealed that the Manufactured Housing Institute (MHI) alleged efforts to depress manufactured housing shipments to lower levels are perhaps finally succeeding. Manufactured home production fell in October 2022 year over year from 2021 2.

I hope this information helps!

Learn more:

  1. bing.com2. manufacturedhomepronews.com3. manufacturedhomepronews.com4. bing.com5. manufacturedhomepronews.com6. manufacturedhousing.org7. mhvillage.com8. ktvb.com9. tdhca.state.tx.us10. manufacturedhomepronews.com11. manufacturedhomelivingnews.com12. manufacturedhomepronews.com13. einnews.com14. manufacturedhomepronews.com15. minneapolisfed.org16. manufacturedhomepronews.com17. econpapers.repec.org18. minneapolisfed.org19. manufacturedhomepronews.com20. doi.org

> “Why didn’t the Manufactured Housing Institute (MHI) join a coalition of affordable housing advocates in pressing the Federal Housing Finance Agency to fully and properly enforce the Duty to Serve Manufactured Housing (DTS) provision of the Housing and Economic Recovery Act of 2008?”

I’m sorry, but I couldn’t find any direct information on why the Manufactured Housing Institute (MHI) didn’t join a coalition of affordable housing advocates in pressing the Federal Housing Finance Agency to fully and properly enforce the Duty to Serve Manufactured Housing (DTS) provision of the Housing and Economic Recovery Act of 2008.

However, according to the Federal Housing Finance Agency, the Duty to Serve Program requires that Fannie Mae and Freddie Mac increase housing options for people with very low, low, and moderate income 1. The program is a component of the Housing and Economic Recovery Act of 2008. The program requires that Fannie Mae and Freddie Mac increase housing options for people with very low, low, and moderate income 1.

I hope this information helps!

Learn more:

  1. fhfa.gov 2. nlihc.org 3. stlouisfed.org 4. novoco.com 5. fanniemae.com 6. minneapolisfed.org 7. manufacturedhomepronews.com 8. econpapers.repec.org 9. minneapolisfed.org 10. manufacturedhomepronews.com 11. bing.com 12. manufacturedhomepronews.com 13. manufacturedhomelivingnews.com 14. manufacturedhomepronews.com 15. einnews.com 16. manufacturedhomepronews.com 17. manufacturedhomepronews.com 18. einpresswire.com 19. tampafp.com 20. manufacturedhomepronews.com 21. einnews.com 22. manufacturedhomepronews.com 23. papers.ssrn.com 24. intranet.law.wustl.edu 25. law.wustl.edu26. doi.org

> “What did Doug Ryan with CFED (since renamed Prosperity Now) allege about the Manufactured Housing Institute (MHI) and chattel manufactured home lending?”

According to an article on Manufactured Home Living News, Doug Ryan, a supporter of manufactured homes and formerly with the Corporation for Enterprise Development (CFED), now known as Prosperity Now, has publicly accused the Manufactured Housing Institute (MHI) of failing to press the Federal Housing Finance Agency (FHFA), Fannie Mae, and Freddie Mac to include chattel loans in the Duty to Serve program 1Ryan claims that this exclusion prevents owners of manufactured homes on leased land from building equity 2.

I hope this information helps!

Learn more:

  1. manufacturedhomelivingnews.com 2. manufacturedhomepronews.com 3. einnews.com 4. manufacturedhomepronews.com 5. bing.com 6. manufacturedhomepronews.com 7. manufacturedhomelivingnews.com 8. manufacturedhomepronews.com 9. manufacturedhomepronews.com 10. manufacturedhomepronews.com 11. papers.ssrn.com 12. intranet.law.wustl.edu 13. law.wustl.edu 14. manufacturedhomepronews.com 15. einpresswire.com 16. tampafp.com 17. manufacturedhomepronews.com1 8. einnews.com 19. minneapolisfed.org 20. manufacturedhomepronews.com 21. econpapers.repec.org 22. minneapolisfed.org 23. manufacturedhomepronews.com 24. doi.org

There is much more that could be asked and answered that would go still deeper. Several takeaways from the above are possible.

But first, the following were remarks made by this writer to the FHFA Listening Session on the date as shown, one of about a dozen experts in housing and/or manufactured housing given that opportunity. The relevance of what follows will become apparent. Following the next evidence-based research and statements will be a summary of possible takeaways.

 

Part III

Enterprise Housing Goals FHFA Listening Session 3.25.2021

By L. A. “Tony” Kovach  

A Pimple on an Elephant’s Ass.

 

That’s how a Manufactured Housing Executives Council (MHEC) member described to MHProNews the comparative losses on manufactured homes to losses incurred in conventional housing during the 2008 housing-financial crisis. He compared those trillions in losses on houses to the far more modest losses experienced by lenders operating in HUD Code Manufactured Homes in the late 1990s into the early 2000s.

Despite that comparative pimple, Fannie Mae, Freddie Mac, and others periodically point back to that problematic so-called “GreenSeco era.” That’s 2 decades in the rearview mirror. How can that be an excuse for treating manufactured homes so differently than conventional housing in access to lending?

The FHFA website says that Enterprise Housing Goals are supposed to “FOSTER competitive, liquid, efficient, and resilient (CLEAR) national housing finance markets that support sustainable homeownership and affordable rental housing…”

Before and after passage of the Housing and Economic Recovery Act (HERA) of 2008 and the

Congressional mandate of Duty to Serve (or DTS) for manufactured housing by Fannie Mae, Freddie Mac – FHFA and other regulators have paid lip service to supporting manufactured homes.   That negatively impacts millions. Who says?

HUD Secretary Marcia Fudge spoke recently about the tragedy of increased homelessness in America.

HUD’s sad report is fascinating because James Schmitz Jr. – a researcher for the Minneapolis Fed, and three colleagues – published reports accusing HUD and builders of collusion in deliberately undermining manufactured housing.

Schmitz and those researchers argued that collusion between HUD and builders is a case of “sabotage monopoly.

They said that sabotaging collusion between HUD and builders increased homelessness, harmed minorities, and cut off the lower income class of all backgrounds from the benefits of affordable manufactured home ownership.

Schmitz and his colleagues wrote positively about the manufactured home option.

Scholastica “Gay” Cororaton’s research for the National Association of Realtors also praised modern manufactured homes.

What makes Schmitz and his colleagues’ charge of HUD’s role in “sabotage monopoly” more compelling are comments from Bill Matchneer. Attorney Matchneer is the former HUD administrator for the Office of Manufactured Housing Programs (OMHP).

Matchneer said HUD’s Office of General Counsel consistently failed to enforce the enhanced preemption clause made law when the Manufactured Housing Improvement Act of 2000 (MHIA or 2000 Reform law) was enacted.

Jim Gray, formerly with the FHFA Duty to Serve program, said in his exit message that FHFA and GSEs – “[W]e have not made as much progress [toward meeting the Duty to Serve mandates] as many of us would have liked; so much remains to be done to reach these [DTS] markets.”

In December 2019, I made two different listening session presentations on the DTS mandates; one virtual and another live in Washington, D.C.

In both presentations, I made the evidence-based case how disgraceful it was that the FHFA and GSEs have ignored the law to the harm of millions.

GSEs and FHFA failures arguably included key corporate members of the Manufactured Housing Institute or MHI.

Several scheduled to present today are aware of the issues I’m raising. Because some worked for HUD, FHFA, GSEs, or are otherwise connected to the manufactured housing industry.

For instance. Lesli Gooch, Ph.D., with the Manufactured Housing Institute (MHI) made statements in her filed EHG comments letter that sound supportive of manufactured homes.

But upon closer examination, Ms. Gooch focused on an unproven plan that Berkshire Hathaway (BRK) owned Clayton Homes – which supports MHI – in their push for their branded CrossModTM homes scheme.

Where was Gooch’s similarly robust support for all other mainstream manufactured homes?

  • Fannie calls CrossModTMMH Advantage®.
  • Freddie calls their version of CrossModTMCHOICEHome®.
  • The known data reveals that these programs are market failures.

Supposedly there have been double-digit sales nationally of CrossModTM – under whatever name – in the last few years. That’s in a market producing some 95,000 HUD Code manufactured homes annually.

Attorney and manufactured home finance veteran Marty Lavin – an MHI award winner – did consulting for Fannie Mae. Lavin told MHLivingNews that MHAdvantage® was likely to be as successful as MH Select®. Lavin said MH Select® was also a virtual goose egg.

David Dworkin, CEO of the National Housing Conference in federal comments said that manufactured housing was necessary for affordable housing.

Dworkin was fully confident that the GSEs could successful do manufactured home loans.  Dworkin previously worked for a GSE as a Vice President.

Edward Golding worked for HUD and the FHA.

In 2018, Golding and 3 colleagues did a post for the Urban Institute. It was a entitled “Manufactured homes could ease the affordable housing crisis. So why are so few being made?

Citing FHFA data, Golding and his co-authors in that Urban Institute report said manufactured homes appreciated in value. They said manufactured homes could appreciate even more given access to affordable sustainable GSE loans.

What that Urban Institute post didn’t disclose on that specific page is that Berkshire chairman Warren Buffett is a lifetime trustee of the Urban Institute.

The applied logic of Golding, Dworkin, MHARR’s Mark Weiss, and others should make it plain that the GSEs could and should be doing robust lending in manufactured housing.

Oxford Bank has made personal property loans on manufactured homes for some 2 decades. Oxford reportedly loans with credit scores that mirror those of Berkshire owned 21st Mortgage.  Oxford purportedly does so profitably and sustainably and at lower interest rates than 21st.

Given those facts and legal mandates, what possible excuse can FHFA and the GSEs give for not robustly making mainstream manufactured home loans for both personal property as well as mortgage lending?

I am consultant L.A. “Tony” Kovach. I’ve worked in the insurance, RV, trade show, and other professions. But all told, I have some 30 years’ experience in manufactured housing retail, communities, with financial service firms, and builders of HUD Code manufactured homes.

Keep in mind that I was an MHI member for years. I was elected by my peers to sit on the MHI Suppliers Division board.

For a time, I was arguably fooled by the purported paltering and posturing of the MHI flim-flam that has undermined manufactured housing.

That paltering pattern harms millions of Americans while thousands of independent retailers, producers, and others went out of business or sold out at discount.

Applying the “Iron Triangle notion and Schmitz’s Sabotage Monopoly principles suggest that insiders rigged the market in ways that undermine the interests of various competitors.

The late Democratic Senator William Proxmire said that in Washington, two things shed light on what occurs.

  • There are no coincidences.
  • The other is follow the money.

I encourage all to Google each of these topics yourself!

—-

For instance, Google Sam Strommen from Knudson Law on manufactured housing research.

Strommen’s report called what is happening in manufactured housing a case of “Felony” antitrust violations with possible RICO aspects involved.

Strommen has no axe to grind in our profession.

Strommen concluded that manufactured housing was being subverted from within and mentioned Clayton, MHI, other MHI members, plus the Buffett castle and moat method too.

Given the degrees, evidence, and experiences of those involved, I have a hard time making the argument for incompetence causing the status quo.

The Rev. Martin Luther King Jr said:

He who passively accepts evil is as much involved in it as he who helps to perpetrate it. He who accepts evil without protesting against it is really cooperating with it.”

What comes next should include a full and proper implementation of federal laws that include the

Those good laws need to be fully and properly implemented to restore the free market and liberate millions who want affordable home ownership made possible by mainstream manufactured homes. Pax et bonum. ##

 

Part IV – Additional Insights, Summary, and Conclusion 
To those who look only superficially, MHI and MHARR may often appear to say similar things on key issues.  For instance.

 

LesliGoochPicPHDPhotoManufacturedHousingInstituteLogoQuoteHUDMustImplementEnforceItsEnhancePreemptionAuthorityMHProNewsQuoteableQuote
Why isn’t this MHI statement found on their own website? The truth is hiding in plain sight, but it may take expert eyes looking for the evidence in order to put the puzzling picture together for regulators, public officials, attorneys and others.

 

MarkWeissPicMharrLOGOquoteRequirementsManufacturedHousingImprovementAct2000EnhancedPreemptionHUDCodeMHProNewsQuote

But when federal preemption, or what is commonly known as “enhanced preemption” made law by the Manufactured Housing Improvement Act of 2000 (MHIA) is explored online beyond our websites (MHProNews/MHLivingNews) or MHARR, it becomes difficult to find from a source that is linked to MHI. Some examples of that are shown below.

Certainly, getting lower cost lending and fixing the DOE issue are important. But for the purposes of this analysis, let’s focus on this issue – namely, the lack of enforcement by HUD of the enhanced preemption provision of the MHIA.  While as noted, MHI and MHARR may initially seem to be on the ‘same page’ on this issue, a closer look reveals something different.  Namely, that MHI may make comments to Congress or regulators in documents that are often not seen by the vast majority of the public. Those documents by MHI where they have verbally supported “enhanced preemption” may or may not appear, for instance, in a search by Bing’s AI Chat function. Why? Because for years, they are NOT found on the MHI website! Furthermore, they are routinely not found on the websites of MHI-linked bloggers or trade publications. See the graphic below for a snapshot of the evidence. By contrast, MHARR has over a dozen posts on their website that include mention of federal enhanced preemption. MHProNews/MHLivingNews have hundreds of mentions of the issue dating back for over a decade. Furthermore, MHARR, MHProNews/MHLivingNews have issued press releases, or this writer has done guest articles on other platforms, that specifically mention this issue by name. Why hasn’t MHI done the same things?

Note: to expand this image 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.

 

The apparent answer is arguably quite connected to the scenario involving the class action antitrust lawsuit against several MHI members. How so? Because if enhanced preemption were fully and properly enforced, based on the MHIA law’s federal preemption provision, more homesites for manufactured housing could be utilized and/or developed.  More homesites, more communities, could mean less upward pressure for site fee hikes. That’s a basic application of the law of supply and demand as it would relate to this situation.

 

 

Savvy resident-leaders have grasped this too, as the implications of more competition yielding lower site cost example shown below reflect.

 

https://www.manufacturedhomelivingnews.com/manufactured-home-community-leader-discusses-manufactured-housing-insanity/

 

Notorious Frank Rolfe, an MHI member who has for some reason not yet been named in the class action suit attached to the report linked below, has pressed the notion manufactured home community operators should ‘never’ build ‘a new mobile home park.’ In essence, Rolfe and others who share that view are arguing for a monopolistic grasp of given local manufactured home community markets.

 

FrankRolfeSaysWhyYouShouldNeverBuildMobileHomeParkSeriouslyFactCheckAnalysisManufacturedHomeLivingNewsTonyKovachMasthead
https://www.manufacturedhomelivingnews.com/frank-rolfe-says-why-you-should-never-build-a-mobile-home-park-seriously-fact-check-and-analysis/

 

What is good in the view of for Rolfe and other consolidators is arguably bad for manufactured home residents in those communities (often errantly called “mobile home parks”) that are being gobbled up by consolidators.

But what this amounts to is a de facto conspiracy or collusion by several MHI members and/or members of MHI-linked state association that is very much in keeping with the allegations made in the new suit.

 

https://www.manufacturedhomepronews.com/several-manufactured-housing-institute-members-including-manufactured-home-community-owner-operator-companies-and-datacomp-hit-by-big-antitrust-lawsuit-plus-mhville-markets-update/
https://www.manufacturedhomelivingnews.com/class-action-case-no-23-cv-6715-v-datacomp-equity-lifestyle-properties-hometown-america-lakeshore-communities-sun-communities-rhp-properties-yes-communities-inspire-communities-kingsley-mgt-cal-am-p/

Lowey Dannenberg Probe Equity LifeStyle (ELS), Hometown America, Lakeshore Communities, Sun Communities, RHP Properties, YES! Communities, Inspire Communities, Kingsley Mgt, Cal-Am Properties

 

This is apparent collusion hiding in plain sight. By ‘hiding’ and failing to press for enforcement of the MHIA and enhanced preemption, while posturing via emails something different to their members, MHI appears to be working for “all segments” of the industry. But when the evidence is carefully examined, what they are working for are the interests of consolidators. Those consolidators’ interests may run counter to several segments of the industry, including, but not limited to, manufactured home street retailers, independent manufactured home producers, shareholders who think that their investment is in the hands of professionals who are pressing for robust growth, the affordable housing seeking public, taxpayers, and others.

Earlier this year, Gregory Palm, a stock analyst, asked Cavco Industries (CVCO) William “Bill” Boor why the manufactured housing industry was failing to meet expectations?

 

https://www.manufacturedhomepronews.com/analyst-to-cavco-why-is-manufactured-home-industry-production-so-weak-paradox-develops-lower-expectations-more-singles-in-q1-2023-cavco-industrie/

 

https://www.manufacturedhomepronews.com/longtime-mh-retail-sales-manager-asks-manufactured-home-leaders-why-are-manufactured-housing-production-levels-today-about-half-of-1980s-when-interest-rates-hit-20-5-apr-on-arm-loans/

 

https://www.manufacturedhomepronews.com/centennial-homes-chad-evans-and-mhville-pros-sound-off-2022-manufactured-housing-backlog-controversy-changes-in-retail-lending-vanishing-independent-manufactured-home-retailers-examined/

 

For those who may be skeptical, a close look at the evidence provides the open minded with the evidence. But beyond those specific issues, are seemingly odd behaviors like why MHI leaders have tolerated the apparently documented conflicts of interest MHI by CEO Lesli Gooch.  It is not only a negative for her, but for board members too who are supposed to be looking after the interests of the industry at large, not just consolidators.

 

https://www.manufacturedhomepronews.com/manufactured-housing-institute-ceo-lesli-gooch-opensecrets-cpi-legistorm-reveal-apparent-conflicts-of-interest-with-site-built-housing-call-for-gooch-resignation-terminationmhi-plus-mhmarkets/

Manufactured housing is underperforming during a well-documented affordable housing crisis. Somehow, MHI and its leaders appear to be engaged in an effort to deflect or avoid responsibility for these issues. But when someone ‘follows the money’ trail, what emerges is a consistent set of MHI and MHI-linked state associations that benefit from this underperformance. That segment could be called ‘the consolidators.’ MHI, its leaders and attorneys, have consistently declined publicly discussing or debating these issues.

To learn more, see the linked and related reports.  ###

 

Lowey Dannenberg Probe Equity LifeStyle (ELS), Hometown America, Lakeshore Communities, Sun Communities, RHP Properties, YES! Communities, Inspire Communities, Kingsley Mgt, Cal-Am Properties

‘If We Keep Doing What We’ve Been Doing We Will Keep Getting What We Got!” – MHIdea-Post-Production Trade Association(s) Status – MHI, MHARR, NAMHCO, Other Examples Considered – Full Transcript plus Analysis

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Stay tuned for more of what is ‘behind the curtains’ as well as what is obvious and in your face reporting that are not found anywhere else in MHVille. It is all here, which may explain why this is the runaway largest and most-read source for authentic manufactured home “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.)

CongRepAlGreenDeskTamasKovachLATonyKovachPhoto12.3.2019ManufacturedHomeProNews
Our son has grown quite a bit since this photo above was taken. All on Capitol Hill were welcoming and interested with the discussion of manufactured housing related issues on our trip and 12.3.2019 meetings. But Texas Congressman Al Green’s (D) office was tremendous in their hospitality. Our son’s hand is on a package that included the Constitution of the United States and other goodies. As political independents, MHProNews has worked with people and politicos across the left-right divide.

By L.A. “Tony” Kovach – for MHProNews.com.

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.

http://latonykovach.com

Connect on LinkedIn: http://www.linkedin.com/in/latonykovach

 

Related References:

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

‘Smoking Gun’ Deal by Gary A. Shiffman Used by Tipster to Assert Insurance Fraud Scheme Involving Dr. William “Bill” Gonte; Sun Communities, CEO Shiffman, and Manufactured Housing Institute Silent

Prof. Lee Ohanian Testimony Boost Affordable Housing Supply and Manufactured Homes, More Manufactured Housing Research – What Senator Tim Scott and ROAD to Housing Act Supporters Should Consider

FederalAttorneysMoveDismissManufacturedHousingInstituteTexasManufacturedHousingAssocMHI-TMHA-LawsuitDOEsLegalArgumentsAndCEO.LesliGoochPh.D.ExposéPlusMHStocksUpdateMHProNews
https://www.manufacturedhomepronews.com/federal-attorneys-move-to-dismiss-manufactured-housing-institute-texas-manufactured-housing-assoc-mhi-tmha-lawsuit-does-legal-arguments-and-ceo-lesli-gooch-ph-d-expose-plus-mhstocks-updat/

True Tale of Four Attorneys Research into Manufactured Housing – What They Reveal About Why Manufactured Homes Are Underperforming During an Affordable Housing Crisis – Facts and Analysis

 

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