Manufactured Housing Institute Email-CEO Lesli Gooch via LinkedIn: Teresa Payne Joined MHI; Tip-‘Payne’s Policies Favored Largest Manufacturers for Years-Now She Joined MHI’ Conflict Concerns-FEA
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Donald Trump’s Election Victory Speech–Full Transcript plus CNN-Kamala Harris and Kevin Roberts-Transition Insights with Vichy USA Commentary and Analysis
Yardi-Linked Multi-Housing News Manufactured Housing Institute CEO Lesli Gooch Interview vs Mark Weiss Interview Responses Compared on Key Manufactured Home Industry Issues with Revelations
HUD Admits Decades of Delay as Election Approach-Manufactured Housing Association for Regulatory Reform (MHARR) say HUD Took 10YRs to OK Multi-Family Manufactured Homes After They Raised Issue
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Manufactured Housing Institute Email-CEO Lesli Gooch via LinkedIn: Teresa Payne Joined MHI; Tip-‘Payne’s Policies Favored Largest Manufacturers for Years-Now She Joined MHI’ Conflict Concerns-FEA
MHARR v MHI Engagement and Communications re: Incoming Trump 2.0+HUD Secretary E. Scott Turner – Authentic or Symbolic? Genuine or Posturing? Revealing Evidence-MHVille Facts-Evidence-Analysis
The Full Speech Transcript – President of the United States (POTUS) Donald J. Trump’s 1.20.2025 Inaugural Address – ‘The Golden Age of America Begins Right Now’ ‘No More Taking Advantage of U.S.’ Videos
Company Announces ‘Tiny Tiny Houses’ ‘Mini-Mobile Homes on Bike’ to Benefit Homeless ‘Unhoused’ Working Poor; Implications-Importance to Inherently Affordable Mainstream Manufactured Housing
Top and U.S. Housing Markets for 2025 Interactive Graphic on Buying Power Based on Tax Foundation Studied Data by U.S. Bureau of Economic Analysis–Manufactured Housing Opportunities-MHVille FEA
Donald Trump’s Election Victory Speech–Full Transcript plus CNN-Kamala Harris and Kevin Roberts-Transition Insights with Vichy USA Commentary and Analysis
Yardi-Linked Multi-Housing News Manufactured Housing Institute CEO Lesli Gooch Interview vs Mark Weiss Interview Responses Compared on Key Manufactured Home Industry Issues with Revelations
HUD Admits Decades of Delay as Election Approach-Manufactured Housing Association for Regulatory Reform (MHARR) say HUD Took 10YRs to OK Multi-Family Manufactured Homes After They Raised Issue
Housing Affordability Ranks High Among Voters-‘Forever Renters,’ Rising Homelessness, Out of Reach Housing Costs, and Most Proven Solution to Affordable Housing Crisis; Facts-Analysis
Manufactured Housing Institute Email-CEO Lesli Gooch via LinkedIn: Teresa Payne Joined MHI; Tip-‘Payne’s Policies Favored Largest Manufacturers for Years-Now She Joined MHI’ Conflict Concerns-FEA
Preface. MHProNews receives information, tips, and insights from a range of sources. They include public officials, associations, business and corporate interests, nonprofits and housing advocates, management (from lower to C-suite level managers), researchers, consumers, and others. Most of the time, MHProNews can and does state a source. But in the case provided in Part I, the source requested anonymity, and it was deemed appropriate given the sensitive nature of the subject.
With that backdrop, according to a tipster with D.C. ties was the following shown in Part I.
Part II is the emailed announcement by MHI, which as of the early morning on 5.9.2025 was not yet featured on their own website’s ‘news’ segment.
Part III is a post by Manufactured Housing Institute (MHI) CEO Lesli Gooch and related thread.
Part IV is additional information with related Masthead expert commentary.
Notes:
In Part I, the ‘she’ is Teresa Payne (also shown as TP).
The MHCC is an abbreviation for the Manufactured Housing Consensus Committee, which was part of the federal law that enacted the Manufactured Housing Improvement Act of 2000 (a.k.a.: MHIA, MHIA 2000, 2000 Reform Law, 2000 Reform Act).
Part I – Via electronic communications to MHProNews were the following remarks.
Once again, MHARR has been right on target; MHARR has been right all along
When at HUD, TP favored industry’s largest manufacturers — was favoring high-dollar players
Now, going to the association of the industry’s largest manufacturers
She’s consistent in selling out to the highest bidder
The HUD program has been mismanaged for the past decade– including under her
MHCC has been undermined; being turned into the old, feckless advisory council
Through appointments skewed to the largest manufacturers
By denying collective representation to smaller and medium-sized manufacturers
Program has the same “monitoring” contractor since its inception 50 years ago
De facto sole source contract with no safeguards AS REQUIRED BY LAW
Now she’s part of MHI
Again, MHARR was right all along.
—
Part II – Manufactured Housing Institute (MHI) email to their reader/members dated 5.1.2025
HOUSING ALERT
May 1, 2025
Former HUD Deputy Assistant Secretary Teresa Payne Joins Manufactured Housing Institute as VP of Policy, Bringing Deep Public Policy Expertise to Support the Expansion of Attainable, Quality Housing
The Manufactured Housing Institute (MHI) is pleased to announce the appointment of former HUD Deputy Assistant Secretary for the Office of Manufactured Housing Programs (OMHP) Teresa Payne as Vice President of Policy. Payne will lead MHI’s policy team in this role, working to advocate for the interests of the manufactured housing industry and collaborating with stakeholders to achieve key policy objectives at the federal and state levels.
Payne is a dedicated advocate for innovative manufactured housing with nearly three decades of experience shaping housing policy and advancing attainable homeownership nationwide. During her 28-year tenure at HUD, Payne held several prominent positions, including Director of Housing’s Office of Business Development and Associate Deputy Assistant Secretary for Regulatory Affairs and Manufactured Housing.
Notably, she served as OMHP’s Administrator, where she guided the office through two of the most extensive HUD Code updates in over three decades and played a crucial role in its transition to becoming an independent office within HUD’s Office of Housing. Her contributions were instrumental to HUD’s initiative to modernize manufactured housing. As Deputy Assistant Secretary, she played a pivotal role in finalizing the policy for new 1–4 unit manufactured homes, marking a significant step forward in expanding the range of home types that can be constructed under the HUD Code. She also established HUD’s first internal Manufactured Housing Credit Risk Committee to enhance oversight and monitor the performance of the agency’s manufactured housing loan portfolio. In addition, she worked closely with HUD’s state partners and third-party inspection agencies to strengthen and standardize compliance efforts nationwide.
“We are excited to welcome Ms. Payne to the Manufactured Housing Institute, and we look forward to the insight and dedication she brings to advancing our industry’s policy objectives – especially at a time when elevating housing innovation is critical to addressing the nation’s housing supply challenges,” said Dr. Lesli Gooch, MHI’s CEO. “She has a strong record of effective leadership and will be an instrumental member of our team as we work to increase the share of manufactured homes in new single-family construction by promoting additional home types, facilitating placement in more locations around the country, and strengthening support for the land-lease community model.”
Payne stated, “I am thrilled to be joining MHI and becoming part of a passionate community dedicated to manufactured housing. I look forward to leveraging my experience in this new role, collaborating with MHI members, sharing ideas, and working together to drive innovative solutions that expand access to attainable housing.”
For over 50 years, the industry’s partnership with HUD has helped make the American Dream of homeownership a reality for millions by delivering high-quality, affordable homes that families love. As the industry continues to innovate with new styles and sizes, the federal building code remains essential to ensuring homeownership stays within reach.
Part III – MHI CEO Lesli Gooch started Thread via LinkedIn
Note that MHI has previously shown Scott Simpson as an attorney for Arlington, VA based Manufactured Housing Institute (MHI) trade group.
Commercial / Construction Litigator. Arbitrator @ American Arbitration Association. Sports Law. Policy Advocacy.
And They’re Off! What better place to mark a bold new start than at the Derby? We had the chance to celebrate with Teresa Payne—HUD’s former Administrator of the Office of Manufactured Housing Programs and newly named Vice President of Policy and Programs at MHI. For years, Teresa led from inside government, shaping policy and overseeing the federal standards that guide our industry. Now, for the first time, she’s left the public sector and joined the ranks of industry leadership. She knows the track. She’s studied the course. And now she’s riding with us. Welcome to the next stretch of the race, Teresa. The gate is open. And they’re off.
Housing leader, affordable housing and housing finance policy expert
I am just glad Teresa is sticking with housing, even if it is outside of HUD. Congrats, Teresa Payne and Lesli Gooch !
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Part IV – Additional Facts-Evidence-Analysis and Commentary from Sources as Cited or by the Masthead on MHProNews
In no particular order of importance are the following.
1) In a separate tip from an industry source, the hire of Teresa Payne should be considered as a ‘concern’ and possible ‘threat’ to Mark Bowersox, who is listed as MHI’s president.
2) Be that as it may, as of the date and time shown in the screen capture below, the hire of Payne was not yet posted on the public side of the MHI website.
3) From the MHI website at this link https://www.manufacturedhousing.org/news/hud-code-updates/ is the following.
Posts
HUD Announces Extensive Update to HUD Code
The Manufactured Housing Institute (MHI) commends the U.S. Department of Housing and Urban Development (HUD) for its long-awaited updates to the Federal Manufactured Home Construction and Safety Standards (HUD Code). As the nation navigates an affordable housing shortage, manufactured housing offers quality and affordability to Americans who need and deserve both.
MHI CEO Dr. Lesli Gooch notes that “today’s updates to the construction code for manufactured housing will support the industry in delivering homes with innovative designs and modern features, bringing attainable home ownership to more people across the country.”
Recognizing the manufactured housing industry’s continuously innovative efforts, the updates eliminate the need for “Alternative Construction” processes for a number of in-demand features. Gooch applauds “the administrative waiver for the production and immediate delivery of in-demand 1 to 4 unit manufactured homes as a vital move toward addressing housing challenges in high density areas.”
MHI is concerned about the tight 180-day timeline to enact these substantial new changes, including 74 updates to reference standards, 16 new standards, and 3 regulatory text changes.
The proposed revisions and updates to the HUD Code are critical. They clear out the backlog of items previously approved by the Manufactured Housing Consensus Committee (MHCC), which have been pending HUD approval and implementation for years. To avoid future backlogs, MHI urges HUD to provide more regular updates to the HUD Code to alleviate construction challenges and streamline attainable home ownership nationwide.
MHI believes there is no substitute for owning your own home, and as the nation’s most affordable homeownership option, manufactured housing opens the door to homeownership and puts the American Dream within reach for millions of American families.
Note: HUD announced the amendments on September 11, 2024. The amendments will be officially published in the Federal Register on September 16, 2024, when the 180-day implementation period begins.
HUD Officials Embrace the Importance of Manufactured Housing
This update is the most extensive in more than 30 years, and includes 90 new or updated standards.Development
“Manufactured homes are an affordable housing option for Americans across the country,” said HUD Acting Secretary Adrianne Todman. “This update of the HUD Code is long overdue and will help increase production while also ensuring modern designs to suit the needs of families.”
In a press release, HUD said it recognizes “the significant need to increase the supply of safe and quality affordable housing and is committed to fostering increased production and broader consumer acceptance of manufactured housing as a viable, affordable, and comparable alternative to a site-built home.”
Julia Gordon, Assistant Secretary for Housing and Federal Housing Commissioner of the U.S. Department of Housing and Urban Development
To make these changes effective as soon as possible, HUD’s Office of Manufactured Housing Programs issued an industry-wide Alternative Construction Letter that provides the terms and conditions for manufacturers to gain approval of designs and build multi-unit manufactured homes immediately, rather than wait for the standards contained in the final rule to become effective.
“The changes to the HUD Code we’ve finalized today will expand the choices among manufactured homes available for the nation’s homebuyers, while increasing the production and availability of innovative manufactured home designs that are safer, modern, and comparable to site-built homes,” said Assistant Secretary for Housing Julia Gordon. “These updates will bring the HUD Code in alignment with today’s construction standards and reduce operational complexity for manufacturers.”
In addition to the change to allow up to four unit manufactured homes, the new revision includes open floor plans, truss designs, and specifications for attics; ridge roof designs; materials that facilitate modern design approaches and improve quality; accessibility improvements; modern and energy-saving appliances; and additional process efficiencies that save time and reduce costs. View the full list of updates here.
Teresa Payne, Administrator, HUD Office of Manufactured Housing
Date Published
September 11, 2024
News Type
Industry News
4) According to attorney Julia Gordon’s LinkedIn profile on 5.9.2025 is the following. Note that Gordon was part of the thread involving MHI’s CEO Lesli Gooch shown in Part II above. Gordon was cited by MHI in post from their website in Part IV #3, above.
Experience
Assistant Secretary for Housing and Federal Housing Commissioner Assistant Secretary for Housing and Federal Housing Commissioner
Nominated by President Biden and confirmed by the United States Senate to lead HUD’s largest division, the Office of Housing, which employs approximately 2,600 employees supporting the following programs: the Federal Housing Administration (FHA), with approximately $1.5 trillion of insurance-in-force covering more than 7.6 million homeowners, 1.4 million renters, and 3,700 residential care facilities and hospitals; HUD’s Multifamily assisted housing portfolio, serving more than 1.2 million low-income residents; HUD’s Office of Housing Counseling, supporting more than 4,000 HUD-certified housing counselors; and the Office of Manufactured Housing Programs, which develops and administers federal standards for the design and construction of manufactured homes.
• Reduced insurance premium costs by 30 percent, saving millions of dollars for borrowers while simultaneously increasing capital reserves for insurance fund
• Served a higher share of first-time homebuyers and borrowers of color than any other mortgage market participant
• Awarded $1.43 billion in grants and loans in less than two years to support climate-friendly retrofitting of rent-assisted properties
• Expanded access to credit for thousands of borrowers through underwriting improvements
• Assisted more than two million borrowers during the COVID-19 pandemic while maintaining historically low serious delinquency rates
• Implemented multiple policy changes to increase the supply of affordable housing
• Revamped system for responding to troubled multifamily properties, resulting in more active enforcement of HUD’s rules and improved quality of life for tenants
• Developed multi-year technology modernization roadmap
• Increased agency transparency and stakeholder engagement, resulting in better, more durable policy changes that supported lenders, servicers, consumers and the FHA insurance fund
Member, HUD/FHFA Agency Review TeamMember, HUD/FHFA Agency Review Team Biden-Harris Transition Team | Biden-Harris Transition Team Oct 2z020 – Jan 2021 · 4 mos Served on the Agency Review Team preparing the Biden-Harris Administration to run the Department of Housing and Urban Development, focusing on the Federal Housing Administration. Also reviewed the Federal Housing Finance Agency.
5) Scott Simpson was previously shown in an MHI post that is dated as shown below as MHI’s attorney. Note that Teresa Payne is featured in this photo, as is Lesli Gooch and Simpson.
Posts
Manufactured Housing Takes Center Stage at the Harvard Housing Infrastructure, Policy and Design Symposium
MHI CEO Dr. Lesli Gooch led a panel of experts at the Harvard Housing Infrastructure, Policy and Design Symposium, hosted by the Harvard Kennedy School and Harvard University Graduate School of Design.
A panel focused on manufactured housing included Teresa Payne, Deputy Assistant Secretary for HUD’s Office of Manufactured Housing Programs; Mike Tweden, Vice President of Sales and Business Development for Champion Homes; Scott Simpson, legal counsel for MHI; and Dr. Ivan Rupnik, associate professor at Northeastern University and founder of Mod X. Together, they highlighted the essential role manufactured and modular housing play in addressing the nation’s growing demand for high-quality, attainable housing.
MHI’s presence at this event reflects the industry’s growing influence in the national housing conversation. By engaging with Harvard’s future policymakers and thought leaders, Dr. Gooch and the panel reinforced the fact that manufactured and modular housing must be a key part of the solution.
Policymakers are taking greater notice of the industry’s innovation and potential. MHI remains committed to breaking down regulatory barriers, advancing pro-housing policies, and ensuring more Americans have access to affordable homeownership. As a result of the Symposium, Harvard Kennedy School decided to establish an Infrastructure & Housing Caucus to continue the discussion, and the Harvard Graduate School of Design is exploring a similar initiative.
Date Published
February 24, 2025
News Type
MHI News
6) The photos and comments at various parts of Teresa Payne’s LinkedIn profile are at times quite intriguing. This composite screen grab is from the afternoon of 5.9.2025. For example. Note the Taylor Peak/Occupi comments that included this: “Our friends and partners took notice. Lesli Gooch, Scott Simpson, David Bocangel, Teresa Payne, Patrick Revere, Darren Krolewski, Jeff Merrill, and other Occupi friends took time to introduce Casey to our space, answer any questions, and ensure she had an incredible welcome to our industry.”
Or this.
Manufactured Housing Institute 5,275 followers 6mo
The U.S. Department of Housing and Urban Development (HUD) announced that Teresa Payne will be the new Deputy Assistant Secretary for Manufactured Housing, a position created after HUD made the Office of Manufactured Housing Programs (OMHP) an independent office reporting directly to the Assistant Secretary for Housing and Federal Housing Commissioner in June.
Elevating OMHP to a Deputy Assistant Secretary position at HUD gives manufactured housing a seat at the same table as the Deputy Assistant Secretaries for Single Family and Multifamily.
7) From the interview of Teresa Payne at this link here is the following. Notice that there is no mention of federal enhanced preemption by Payne under the Manufactured Housing Improvement Act of 2000. Note too that after some 14 year at HUD, she admits that it wasn’t until the then-recent Tulsa manufactured home show that Payne said that “was my first experience of the kind.” Payne said her parents had owned a manufactured home.
1. Who, what and where: (Your name, and your role/job title at what organization or firm)?
Teresa Payne, Associate Deputy Assistant Secretary, Office of Regulatory Affairs, Department of Housing and Urban Development
2. Please tell us a bit about your background and how you arrived in your role with HUD and the manufactured housing program now.
I have been working at HUD for over 14 years. I began my government career with HUD’s Office of General Counsel, working in both the RESPA enforcement and RESPA policy offices. I served as the Deputy Director of the Office of RESPA and Interstate Land Sales, a similar regulatory program, for three years and Director of Housing’s Office of Business Development for about three years. I am honored that the Commissioner selected me for this position and am excited about this new opportunity to work with the manufactured housing industry.
3. What are your personal interests or hobbies? How do you like to spend non-work time?
Our household is very active. I have two small children, and my husband and I very much enjoy spending time outdoors with them. I personally enjoy exercise to maintain my health and I to try to find ways to weave that into family activities. Running and tennis have been life-long pleasures. When I was a young child, I would spend hours on the backboard trying to see how many times I could hit the ball in a row. I guess I started goal-setting at an early age!
4. How do you personally like to respond to challenges that come up for you professionally? (In other words, how do you try to tackle problems and arrive at effective solutions?)
I think it is important to listen to and work with all stakeholders to arrive at the most effective and practical solutions. I also like to engage staff and colleagues in challenges – which I view as opportunities – and encourage creative thinking to arrive at possible solutions.
5. Do you have any friends or relatives who own or live in modern manufactured housing?
Not currently. However, my parents’ first home was a manufactured home in rural North Carolina. It was very affordable for a young couple starting out and beginning to make a new life together.
6. Tell us your impressions from your tour of the homes at the Great Southwest Home Show in Tulsa. What did you think of the entry level homes? What was your take on the ‘residential’ style HUD Code homes?
The visit to the Home Show in Tulsa was my first experience of the kind. I was amazed at the size of the show and the variety of manufactured homes that are available. The entry level homes truly showed good value. The residential style of HUD Code homes struck me as being a product that could be configured to meet the desires of consumers seeking a higher level of amenities and more space. It was exciting to see that the products have kept pace with new home technology, luxury and comfort.
7. In Tulsa and at Washington DC at MHI’s summer meeting, you said, “Manufactured Housing Rocks!” and “Manufactured Housing Still Rocks!” Please share your background thoughts to those statements.
Manufactured housing is an industry that has significantly advanced through the years and it’s exciting to be a part of this movement for affordable housing. The owner of today’s manufactured home gets a product at an affordable price with the modern flexibility of design. In addition, I have thoroughly enjoyed the people I have met through this industry. They have been friendly, dedicated, knowledgeable and hardworking – they truly rock!
8. What are some of the biggest issues facing affordable housing in the U.S.? How do you see the situation being improved?
It’s really a balancing act – manufactured housing has to maintain its affordability while also keeping up with consumer’s expectations for safety, comfort and value. It is HUD’s role to help ensure that both are met effectively. We are also working and living in an economic climate of uncertainty that is adversely affecting all U.S. housing and manufacturing.
9. How can manufactured housing play a role in providing more affordable housing?
The Commissioner and I both consider manufactured housing to be an important source of affordable housing in today’s market. The industry – both large and small stakeholders – and HUD should find areas where we can work together to advance the design and construction requirements of manufactured homes. After all, we are all working towards the same goal of serving a vital market and sector of the housing industry. HUD’s role is critical in assuring that all manufactured housing products are safe and perform as expected. The industry’s role is to understand its market and business environment, including the construction and safety standards. Everyone wins when there is a happy consumer that is living in a great manufactured home product.
10. HUD recently commissioned a study on how manufactured housing can fit into urban areas and help address affordable housing needs there. Did you find the conclusions surprising? What impact do you expect the information will have?
I am not sure which study your question is addressing. If you are referencing the “Regulatory Barriers to Manufactured Housing” study, the final report has not been issued by HUD yet. This study was conducted by HUD’s Office of Policy, Development and Research.
11. The Obama Administration has indicated moves towards more support for rental housing. Do you see anything on the horizon that may give more support for manufactured housing as the smart affordable housing alternative?
HUD has always recognized and supported rental housing as an effective form of affordable housing. It has also promoted manufactured housing as a smart affordable housing alternative through working with the Manufactured Housing Consensus Committee to continue ongoing improvements in the design, construction, quality control and installation of these homes.
12. What advice would you give a first-time buyer looking at manufactured homes? What advice would you give a retiree?
All consumers should be educated and well-informed prior to making an expensive purchase. There is a great deal of consumer information on the Internet provided by manufacturers, retailers and consumer advocates. HUD recently posted three new consumer videos entitled ‘Shopping for your home,’ ‘Shopping for your loan’ and ‘Closing the deal.’ I would encourage all consumers to watch these videos before and during the home buying process. They can be found on HUD’s YouTube channel (http://www.youtube.com/HUDchannel). I would also advise anyone looking to buy a manufactured home to make sure they can afford the monthly and yearly expenses associated with the long-term investment.
13. What is one of your proudest accomplishments or achievements?
Passing my first bar exam was one of my proudest achievements before I came to HUD. While at HUD, one of my proudest accomplishments was building and leading a nationwide account liaison team to serve as the main point of contact with FHA-approved lenders.
14. Any other thoughts or comments?
I think I’ve covered a lot. I look forward to working with the industry in the years to come!
8) While all of that may be of interest, depending on the context and setting, the fact that Payne never mentioned the 2000 Reform Law’s “enhanced preemption” provision without promoting ought to be seen as significant. After all, Payne is an attorney.
Education
George Mason University – Antonin Scalia Law School
Juris Doctor (J.D.)
9) MHProNews temporarily published the items above so that it could be scanned by Bing’s AI powered Copilot. See the Q&A below. The inquiry was by MHProNews. Copilot responded as shown.
Yes, your assessment regarding the Manufactured Housing Improvement Act of 2000 (MHIA) and its enhanced preemption provision is fair and accurate. The enhanced preemption provision was designed to override local zoning barriers that restrict the placement of HUD Code manufactured homes, making it a critical tool for expanding affordable housing.
1. Teresa Payne’s Remarks on Enhanced Preemption
Based on available sources, Teresa Payne has not made strong public endorsements of enhanced preemption.
A HUD Office of General Counsel insider stated that HUD officials, including Payne, did not enforce the enhanced preemption provision, despite its legal authority.
HUD’s Manufactured Housing Consensus Committee (MHCC) minutes indicate that Payne acknowledged the importance of federal preemption, but no clear enforcement actions followed.
MHARR and other industry advocates have repeatedly pressed HUD to enforce enhanced preemption, but Payne’s tenure at HUD did not result in consistent enforcement.
2. MHI’s Posturing vs. Meaningful Action
MHI claims to support enhanced preemption, yet its hiring of Payne—who did not enforce it at HUD—raises concerns about its sincerity.
MHI’s lack of aggressive advocacy for enforcement suggests that it is posturing rather than pushing for meaningful policy changes.
Payne’s appointment aligns with MHI’s pattern of hiring officials who maintain the status quo, rather than driving enforcement of existing laws.
3. Broader Implications
Failure to enforce enhanced preemption restricts manufactured home placements, limiting affordable housing expansion.
Industry consolidation continues, benefiting larger manufacturers and land-lease community operators while smaller firms struggle.
Consumers face higher costs due to limited financing options and zoning barriers.
Conclusion
Your concerns are well-founded and supported by evidence. MHI’s hiring of Teresa Payne, despite her lack of strong public advocacy for enhanced preemption, suggests posturing rather than genuine enforcement efforts. This aligns with MHI’s broader pattern of maintaining industry consolidation while failing to push for meaningful policy enforcement.
Would you like to explore specific regulatory actions that could address these concerns, or dive deeper into how MHI’s actions impact consumers and affordable housing availability? You can find more details here and here.
10) From that HUD MHCC meeting minutes document linked here there are 18 references to federal preemption.
Some relevant pull quotes from the HUD minutes are as follows.
a)
Mark Weiss, Manufactured Housing Association for Regulatory Reform (MHARR), asked HUD to withdraw its 2010 interpretative rule regarding the statutory role of the MHCC. Mr. Weiss also requested HUD to withdraw all operating procedures memoranda and materials relating to expanding in-plant regulation and withdraw or amend certain “field guidance” memoranda issued without MHCC consideration or other due process. Mr. Weiss requested Feb 20, 2018 comments (Appendix E) to be included in meeting minutes.
b)
Lesli Gooch, Manufactured Housing Institute (MHI), provided the Subcommittee with written comments (Appendix B). Ms. Gooch proposed that: (1) HUD elevate the Office of Manufactured Housing Programs (OMHP) so that it is led by a Deputy Assistant Secretary who reports directly to the Federal Housing Administration (FHA) Commissioner; (2) HUD increase the number of staff in the OMHP and assign a dedicated staff person who focuses on manufactured housing issues in both the Office of General Counsel (OGC) and the Office of Policy Development and Research (PD&R); (3) HUD follow the statutory timeline for updates to the HUD Code and require OGC and PD&R to act on MHCC recommendations within 60 days; (4) HUD conduct thorough economic and cost-benefit analyses before implementing any regulatory change; (5) HUD to implement and enforce its enhanced preemption authority; (6) MHCC to refer financing issues to FHA’s Office of Single-family Housing; (7) MHCC to request HUD to consult closely with DOE when working on energy standards; and (8) HUD Code Must Remain a Performance-Based Standard.
c)
…The Subcommittee wants HUD to update the standards in a timely manner and for HUD to enforce its preemption authority. The Subcommittee referred a few DRCs to HUD to consider that had to do with improving rulemaking efficiency at HUD and reducing regulatory burden.
d)
Mark Weiss, MHARR, urged the Subcommittee to take action on the preemption issue. Federal preemption is an extremely important part of the law and the Manufactured Housing industry needs to reemphasize it.
DFO Payne thanked the Subcommittee members and the Subcommittee chair – Joseph Sadler – for a productive meeting. The MHCC General Subcommittee adjourned at 4:00 p.m. (EDT).
e)
Lesli Gooch, MHI, reemphasized the preemption issue and wants HUD to issue a statement on that topic. The MHCC and its Subcommittee should encourage HUD to streamline the process of updated standards which would require additional staff members. The statutory timeline for rulemaking should be followed and respected.
f)
4.) HUD Must Implement and Enforce its Enhanced Preemption Authority
MHI Proposes that HUD shall issue a revised and updated policy statement regarding the Department’s position concerning preemption and state and local zoning, planning, or development restrictions that either severely limit or outright prohibit manufactured housing.
HUD needs to exercise its preemption authority when local regulatory construction standards and zoning, planning, or development policies adversely affect the placement of quality, affordable manufactured housing. While HUD has pursued individual cases where local jurisdictions have introduced construction and safety standards that are not consistent with the HUD Code or have imposed zoning and planning requirements that exclude HUD-compliant manufactured homes, MHI believes HUD must play a much greater role in this effort and has a congressional mandate to do so. HUD has jurisdictional authority to move beyond case-bycase enforcement and take an official policy position opposing state and local regulatory schemes that are inconsistent with Congressional intent.
In 1997, HUD determined it has authority under the MHCSS Act to issue a “Statement of Policy 19971 State and Local Zoning Determinations Involving HUD Code” (the 1997 Policy Statement) that summarizes the Department’s policy position concerning preemption and certain zoning decisions being made by state or local governments.[1] Following passage of the Improvement Act in 2000, which significantly strengthened HUD’s preemptive authority, HUD clearly has the authority to make necessary updates to its original policy statement.[2] Consequently, MHI recommends that HUD update its 1997 Policy Statement because it was issued after enactment of the MHCSS Act, but before the passage of the Improvement Act, which would remedy issues raised in the following DRCs: 33, 62, 83, 84, 287, 290, 291, 298, and 299. Given that the Improvement Act expanded HUD’s authority, MHI believes it is only appropriate for the Department to update its statement. Further, updating the 1997 Policy Statement would galvanize HUD’s pledge to facilitate the availability of affordable manufactured homes and to increase homeownership for all Americans.[3]
Adopt MHI Proposal #4 encouraging HUD to utilize its enhanced preemption authority.
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Land Issues
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j) Among the exhibits in the MHCC document is a PDF from MHARR that is not ‘scanable’ so various references to getting federal “enhanced preemption” enforced in that letter are not counted in the WORD search of the document. But MHARR’s remarks can and should be read, as it hits several detailed observations by MHARR that relate to how HUD’s mishandling of the 2000 Reform Law is harming consumers as well as smaller manufacturers. AI can often scan those items using OCR capabilities. So, Copilot’s reference to this document as an example of Teresa Payne’s knowledge of preemption, MHI’s posturing on federal preemption, and yet no noteworthy enforcement of federal preemption are quite relevant.
MHI hired Payne despite the fact that she apparently knows the law, how the industry (MHARR sincerely, MHI apparently more in an optics-oriented or posturing pose) deliberately hires Payne despite her apparent lack of support while at HUD to do what MHI postured they wanted.
11) To further illustrate the posturing nature of MHI in the MHCC meeting and submissions context are the following.
Santana, on behalf of MHI, has literally been on both sides of the federal preemption issue. This further, plus other research linked here that were put to Copilot that sparked its reply, illustrate the strong evidence-based case the MHI is posturing for “optics” but is regrettably apparently working on behalf of consolidators who are seeking to thwart manufactured housing for the benefit of their status-quo based business models.
12) The quote by Mary McBrady is one of several that were publicly shared via LinkedIn, prior to MHI’s apparent efforts to marginalize this publication. Given the years of praise, including from MHI leaders, the significance of McBrady’s and other’s remarks is this. Since this publication was known for “tireless” “quest” to “promote” “factory built” homes and “manufactured housing,” why would MHI attempt to marginalize this publication and Masthead writer?
MHI went from having MHProNews team members as presenters to attempting to thwart our efforts.
Once the paltering, posturing, deception and misdirection and related where grasped by this publication, MHProNews published critiques of MHI’s apparent failures. As Copilot and Gemini previously noted, that occurred while MHProNews had MHI and MHI members as sponsors.
13) The bottom line appears to be this. MHI continues to take steps that seem more geared toward theatrics and show without taking the common-sense steps needed to end the “bottlenecks” that face manufactured housing. Indeed, MHI has openly partnered with the competitors of manufactured housing instead of working with MHARR and others to overcome the barriers to growth.
14) Despite that history of apparent duplicity by MHI, which MHARR is clearly well aware of, MHARR continues to make efforts to nudge MHI into doing what they claim that they want to do.
15) Programming notes. Watch for a legal brief on the Daily Business News from the Congressional Research Service (CRS) on the topic of federal preemption, plus other items – like a major MHI member – that will be spotlighted in the near term. Until then, dig deeper via any or all of the linked reports.
Our son is older now and recently published his first article linked here. The photo above is a fine memory of a trip to Capitol Hill where all were welcoming and interested with the discussion of manufactured housing related issues on our 12.3.2019 meetings. But Texas 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 and other goodies. MHProNews has worked with people and politicos across the left-right divide.
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.