The Washington, D.C. based Manufactured Housing Association for Regulatory Reform (MHARR) made the following statement in a release to MHProNews. This will be followed by additional information from MHARR. Some analysis and commentary will follow.
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FOR IMMEDIATE RELEASE Contact: MHARR
MHARR ADMONISHES HUD SECRETARY FOR OMITTING
MANUFACTURED HOUSING FROM LIST OF AGENCY ACCOMPLISHMENTS
Washington, D.C., May 20, 2021 – The Manufactured Housing Association for Regulatory Reform (MHARR) in a May 13, 2021 communication to HUD Secretary Marcia Fudge (see, Attachment 1), has admonished the Department and its leadership under the Biden Administration for failing to include or mention the advancement of inherently affordable, non-subsidized manufactured housing among various activities HUD is undertaking to address “urgent housing needs” and establish “the foundations to tackle longer-term housing challenges.”
Specifically, in a May 6, 2021 News Release titled “Fact Sheet: HUD at 100 Days,” (see, Attachment 2) the Department sets out what it considers to be “key accomplishments” thus far under the Biden Administration, as well as goals and objectives relating to both housing and broader community development, including “affordable housing.” Nowhere, though, does the Fact Sheet, include, address, or even mention the inherently affordable, non-subsidized manufactured homes that HUD itself regulates. Thus, while the so-called “Fact Sheet” lauds and details more than $31 billion in subsidies and other expenditures of federal taxpayer funds to supposedly promote “affordable housing,” it ignores – and would indicate that HUD as an agency is ignoring – the inherently affordable manufactured housing that it is responsible for not only regulating, but also advancing in accordance with the purposes and congressional objectives of the Manufactured Housing Improvement Act of 2000.
As a result, MHARR’s communication calls on Secretary Fudge to take steps now to address and rectify the four major barriers (i.e., full program reform in accordance with the 2000 law; elimination of discriminatory and exclusionary zoning; revitalization of the Federal Housing Administration’s Title I manufactured housing program; and full implementation of the Duty to Serve) that continue to impede the evolution and growth of the industry, as well as the fulfillment of its enormous potential to meet and satisfy the nation’s growing need for affordable homeownership. By resolving these issues, Secretary Fudge and the Biden Administration would not only help provide affordable housing and homeownership for millions of lower and moderate-income American families, but also preserve billions of dollars in funding that could be used for other efforts.
In Washington, D.C., MHARR President and CEO, Mark Weiss, stated: “Manufactured housing is the embodiment of the type of affordable homeownership that the Biden Administration has indicated it wants to make available on an equitable basis for all Americans. By its very nature, manufactured housing is a great ‘equalizer,’ that is available and accessible to nearly every American regardless of income, race, class, creed, or any other factor. As such, and in accordance with existing federal law, the Biden Administration – and especially HUD – should be doing everything within their power to ensure that inherently affordable, non-subsidized, federally-regulated manufactured housing is fully available as a viable homeownership option for all Americans, without any extraneous, baseless restraints.” Weiss continued, “On behalf of the entire industry, but most importantly, its smaller, independent businesses, we look forward to working with Secretary Fudge and the Biden Administration in order to make this a reality.”
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 —
Manufactured Housing Association for Regulatory Reform (MHARR)
1331 Pennsylvania Ave N.W., Suite 512
Washington D.C. 20004
MHARR also included the following letter. The text of that letter below covers some of the same ground. But it also adds some additional wrinkles, insights, and requests that merit the attention of industry professionals and all other interested parties, for reasons that will become evident.
This letter was addressed to HUD Secretary Fudge, but also to senior Democratic and Republican leaders in Washington, D.C.
May 13, 2021
VIA FEDERAL EXPRESS
Hon. Marcia Fudge
U.S. Department of Housing and Urban Development Suite 10000
451 7th street, S.W.
Washington, D.C. 20410
Re: The Omission of Affordable Federally-Regulated Manufactured Housing from the “HUD at 100 Days” Report
Dear Secretary Fudge:
I am writing on behalf of the members of the Manufactured Housing Association for Regulatory Reform (MHARR). Manufactured homes, as you know, are comprehensively regulated by the U.S. Department of Housing and Urban Development (HUD) pursuant to the National Manufactured Housing Construction and Safety Standards Act of 1974 (42 U.S.C. 5401, seq.), as amended by the Manufactured Housing Improvement Act of 2000 (2000 reform law). MHARR’s members are mostly smaller and medium-sized independent producers of HUD regulated manufactured housing, situated in all regions of the United States.
We have read with great interest the recently-published “HUD at 100 Days” Fact sheet. That document addresses, in substantial part, HUD’s efforts, under the Biden Administration, to address homelessness and increase the availability of affordable housing for American families through federal grants and other types of funding provided to public housing authorities and related government-based entities. And while we applaud these initiatives, as well as the Administration’s broader focus on promoting affordable housing and homeownership, we are extremely disappointed and surprised that neither HUD — nor you, as HUD Secretary — have thus far embraced or expressly recognized (either in this Fact Sheet or through other actions to date) the critical role of manufactured housing, re lated b HUD itsel , in providing a private-sector resource to address and remedy both homelessness and the critical need for affordable homeownership in the United States.
The U.S. Congress, long ago, recognized the unique status of manufactured housing as the nation’s premiere source of inherently affordable, non-subsidized housing and homeownership, and has acted consistently to protect, expand and advance both the affordability and availability of manufactured homes for all Americans and, most especially, lower and moderate-income families.
As a result, Congress provided for the regulation of manufactured housing production and safety under uniform, federally-preemptive standards under the 1974 Act as subsequently updated, modernized and strengthened by the 2000 reform law. Then, when Congress saw that the availability of consumer financing for manufactured homes was a significant restraint on their wider availability and utilization, it acted to advance support by both the Federal Housing Administration (FHA) and the Government Sponsored Enterprises (GSEs) (i.e., Fannie Mae and Freddie Mac) for the manufactured housing consumer loan market in the Housing and Economic Recovery Act of 2008 (HERA). Specifically, as part of HERA, Congress increased the value of manufactured home consumer loans that would be eligible for FHA underwriting, and mandated the securitization and secondary market support of manufactured home consumer purchase loans by Fannie Mae and Freddie Mac as part ofthe statutory Duty to Serve Underserved Markets (DTS).
Unfortunately, though, years and, in some cases decades later the manufactured housing industry and American consumers of affordable housing continue to face serious obstacles and intentional discrimination that, combined with baseless resistance to the full and proper implementation of these good laws within relevant federal agencies, have undermined the full realization of Congress’ laudable objectives. These barriers, which, in combination, have prevented the industry from supplying millions of lower and moderate-income Americans with high-quality, inherently-affordable homes, include the following:
- HUD’s continuing failure to fully and properly implement all program reforms of the 2000 reform law, including its ongoing maintenance of an archaic and dysfunctional contract-based regulatory system which needlessly increases regulatory compliance costs for both the industry and consumers;
- Discriminatory local zoning restrictions and exclusions that HUD has failed — and continues to fail — to correct and eliminate through the full and proper implementation of the enhanced federal preemption authority enacted by Congress as part of the 2000 reform law;
- Decimation of the FHA Title I manufactured housing finance program as a result of excessive Government National Mortgage Association (GNMA) regulatory criteria for the securitization of insured manufactured housing lenders; and
- The decade-and-a-half failure of Fannie Mae and Freddie Mac with the de fagLQ approval of the Federal Housing Finance Agency (FHFA) to implement the DTS mandate with respect to manufactured housing and manufactured home consumer financing. Although this mandate falls under the regulatory jurisdiction of FHFA, the industry believes and maintains that, based on the entirety of federal manufactured housing law, the Secretary of HUD, as the de facto “guardian” of federal superintendence of the manufactured housing industry, has an obligation and responsibility to address and resolve this matter for the benefit of American consumers of affordable housing.
The ultimate consequence of all the foregoing has been — and continues to be — a severe shortfall in the availability of inherently affordable manufactured housing, as part of a broader deficit in the availability of much-needed entry-level, “starter homes,” as recently documented by an April 2021 Freddie Mac analysis.
Based on all of this, we hope that you can understand and appreciate our extreme disappointment and dismay at the exclusion of affordable, high-quality manufactured housing the regulation of which HUD fully and completely controls, from the recitation of HUD’s top level housing priorities, as reflected in the Department’s “First 100 Days” news release. Given your background in housing, as well as your Senate confirmation hearing testimony, we can only surmise that this omission is an outgrowth of either: (1) a lack of relevant and appropriate input from HUD staff; or (2) a lack of crucial information and input as a consequence of not having yet communicated directly with industry representatives. We say this, and our concern arises from the fact that, this is the first time in our collective memory that a new HUD Secretary has not had direct interaction and engagement with MHARR as the national representative of the smaller, independent businesses which constitute the traditional nucleus of the manufactured housing industry within the initial months of their tenure.
We thus view a direct meeting with you to be an urgent matter for both the industry and the millions of Americans who rely on manufactured housing as a primary resource for affordable homeownership. Consequently, we will contact your office soon to pursue a meeting to address these matters.
Again, we welcome your confirmation as HUD Secretary, and look forward to speaking with you directly.
President & CEO
cc: Hon. Joseph R. Biden
Hon. Kamala Harris
Hon. Sherrod Brown
Hon. Patrick Toomey
Hon. Maxine Waters
Hon. Patrick McHenry
Hon. Mark Calabria
To the points MHARR raised about failure to implement the Manufactured Housing Improvement Act of 2000 (MHIA or 2000 Reform law), the following pull quotes underscore the points made by MHARR.
Put differently, the fact- and evidence-based MHARR has the facts on their side. It is now a question if Secretary Fudge was just posturing for the Senate when she made pro-manufactured housing statements, or if she was indeed sincere in those comments. But in fairness, something similar could be said about the FHFA.
More than 100 days in, there is no sign yet – as Weiss stated above – that Fudge is serious about seeing more affordable home ownership via HUD Code manufactured homes. Time will tell, and MHProNews will monitor and report either way. See the linked and related reports to learn more. The Friday evening manufactured housing connected equities for 5.21.2021 and related market insights at the close yesterday follow the linked reports.
Notice: While the layout of this business daily report has recently been modified, several elements of the basic concepts used previously are still the same. The headlines that follow below can be reviewed at a glance to save time while providing insights across the left-right media divide. Additionally, those headlines often provide clues as to possible ‘market moving’ reports.
Market Indicator Closing Summaries – Yahoo Finance Closing Tickers on MHProNews…
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Manufactured Housing Industry Investments Connected Closing Equities Tickers
Some of these firms invest in manufactured housing, or are otherwise connected, but may do other forms of investing or business activities too.
- NOTE: The chart below includes the Canadian stock, ECN, which purchased Triad Financial Services, a manufactured home industry lender
- NOTE: Drew changed its name and trading symbol at the end of 2016 to Lippert (LCII).
- NOTE: Deer Valley was largely taken private, say company insiders in a message to MHProNews on 12.15.2020, but there are still some outstanding shares of the stock from the days when it was a publicly traded firm. Thus, there is still periodic activity on DVLY.
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That’s a wrap on this installment of “News Through the Lens of Manufactured Homes and Factory-Built Housing” © where “We Provide, You Decide.” © (Affordable housing, manufactured homes, stock, investing, data, metrics, 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.)
By L.A. “Tony” Kovach – for MHLivingNews.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.