MHARR Calls on HUD Secretary E. Scott Turner to Probe and Reform HUD Code Manufactured Housing Program. ‘HUD/OMHP Manipulation of MHCC.’ ‘Anti-Small Biz Bias.’ More MHVille FEA

“MHARR, in an August 12, 2026 communication to HUD Secretary Scott Turner (redacted copy attached), has called for a complete investigation of – and fundamental wide-reaching reforms to – the operation of the federal manufactured housing program administered by HUD’s Office of Manufactured Housing Programs (OMHP).” Less than two weeks after this message was conveyed to HUD Secretary E. Scott Turner and subsequently to manufactured housing industry professionals, it seems that HUD has begun to respond (see that in our Sunday weekly recap). As of the date and time shown here, the Manufactured Housing Institute (MHI) has made no similar public claim nor has MHI reported on this topic and the related Sunday topic. Indeed, it seems that MHI leaders are so important and so busy that they simply don’t have time to share ANY public facing news in August 2026, as the annotated screen capture below documented.

Oh, those pesky facts.

Per Grok in Part III #5.

This does not prove motive but supplies a verifiable baseline for evaluating claims of representing “all segments.”

Per Gemini in Part III #3.

The silence from MHI, despite explicit statements by legal counsel David Goch confirming MHI monitors industry criticism, points to calculated strategic avoidance.

…

This FEA check serves as a vital addition to the research base published on MHProNews and MHLivingNews, validating how administrative and trade association dynamics actively impede affordable housing growth in the United States.

This MHVille facts-evidence-analysis (FEA) is underway.

Part I. From the Manufactured Housing Association for Regulatory Reform (MHARR) press release originally published here.

AUGUST 17, 2026

TO:                 HUD CODE MANUFACTURED HOUSING INDUSTRY MEMBERS
FROM:          MHARR
RE:                 MHARR CALLS ON HUD SECRETARY TO FUNDAMENTALLY REFORM FEDERAL MANUFACTURED HOUSING PROGRAM

MHARR, in an August 12, 2026 communication to HUD Secretary Scott Turner (redacted copy attached), has called for a complete investigation of – and fundamental wide-reaching reforms to – the operation of the federal manufactured housing program administered by HUD’s Office of Manufactured Housing Programs (OMHP).

Citing multiple examples of irregularities, manipulation and potential “inside-outside” coordination of key functions and aspects of the HUD program – all to the extreme detriment of the industry’s smaller mainstream businesses — MHARR seeks, and has requested that the Secretary undertake, a full and independent investigation of the OMHP with regard to – among other things:

1. HUD/OMHP manipulation of Manufactured Housing Consensus Committee (MHCC) appointments;
2. Repeated, overlapping MHCC appointments for certain favored persons/entities;
3. HUD/OMHP exclusion of collective small business voting representation on the MHCC;
4. Targeted, biased HUD/OMHP rejections of independent MHCC nominees;
5. HUD/OMHP manipulation of MHCC procedures and processes to exclude small business representation and input;
6. Overall anti-small business bias in the operation of the MHCC and other HUD/OMHP functions;
7. A near-total lack of transparency regarding OMHP actions, policies and decisions including, but not limited to failure to comply with multiple Freedom of Information Act requests;
8. Evidence of possible “inside-outside” coordination related to former program officials;
9. A total failure to implement the enhanced federal preemption of the Manufactured Housing Improvement Act of 2000; and
10. A failure to conduct legitimate competitive solicitations for the program monitoring contract or to comply with sole-source contract safeguards, resulting in the selection of the same program contractor for the entire 50-year history of the program.

While the legitimate functionality of the HUD program gained some ground in the immediate aftermath of the enactment of the landmark Manufactured Housing Improvement Act of 2000 (2000 Reform Law) and took additional steps toward a more even-handed approach with the reassignment and replacement of its former administrator during the first Trump Administration, OMHP – particularly over the years of the Biden Administration – has steadily regressed back to the type of biases, regulatory excesses and anti-small business practices that were commonplace prior to 2000. This specifically includes – and centers upon – a worsening abuse and manipulation of the MHCC and its processes.

Designed by the 2000 Reform Law to be the centerpiece of a reformed HUD program with uniform, consensus-based performance standards, federally-coordinated enforcement, robust federal preemption and related practices, and to serve as a bulwark against excessive and excessively costly regulation, the MHCC, its membership and its activities, are being increasingly corrupted and twisted to serve the interests of HUD and the industry’s largest corporate conglomerates. Effectively, then, the MHCC, instead of serving as an independent, fair, balanced and unbiased guardian of the affordability and reasonable regulation of the manufactured housing industry – as expressly stated by the 2000 Reform Law – is steadily becoming little more than a clone of the toothless former Manufactured Housing Advisory Council, which it replaced under the 2000 Reform Law.

All of these irregularities, as detailed extensively in the MHARR communication, point to a program that continues to be mismanaged, continues to violate key elements and aspects of the 2000 Reform Law – including the broad and liberal enforcement of its enhanced federal preemption in order to prevent the discriminatory zoning exclusion of HUD-regulated manufactured homes from communities around the nation – and continues to fail both the industry (and especially its smaller businesses) and the millions of American consumers who rely on mainstream manufactured homes for affordable housing and homeownership.

The need to fundamentally correct and reform the federal program is especially urgent now – and essential to the survival and prosperity of the industry’s mainstream core – given the failure of the Manufactured Housing Institute (MHI)-supported 21^st Century ROAD to Housing Act (ROAD Act) to address and fully remedy the major regulatory bottlenecks (i,e., discriminatory and exclusionary zoning restrictions and impending unnecessary high-cost “energy” regulation) which continue to suppress the production, placement and sale of federally-regulated manufactured homes (together with the failure of Fannie Mae and Freddie Mac to implement the statutory Duty to Serve with respect to manufactured home consumer chattel loans which the ROAD Act also fails to address). Without a statutory remedy in the ROAD Act, these key issues must now be addressed and rectified within the HUD regulatory system, through an MHCC and MHCC process that has been fully reformed to comply with all aspects of the 2000  Reform Law and not the current MHCC/MHCC process which has been hijacked, tainted, distorted and mismanaged by the HUD program. It is urgent to the fundamental legitimacy and validity of the federal program that all industry members and consumers support such necessary reforms to prevent further lawlessness.

To resolve these crucial deficiencies, defects and failures, will specifically require the direct involvement and leadership of Secretary Turner. Alternatively, Secretary Turner should – at long last – provide for an appointed non-career Administrator/Deputy Assistant Secretary for the HUD program, who would report to, be accountable to  – and be directly supervised – by him. Through such leadership, MHARR believes that the federal program can finally be brought to full, fair and objective compliance with all reform elements of the law for the benefit of the entire industry and Americans in need of affordable homeownership.

MHARR will continue to aggressively pursue this initiative going forward and will advise you accordingly.

Attachment

Manufactured Housing Association for Regulatory Reform (MHARR)
1331 Pennsylvania Ave N.W., Suite 512
Washington D.C. 20004
Phone: 202/783-4087
Fax: 202/783-4075
Email: MHARRDG@AOL.COM
Website: www.manufacturedhousingassociation.org

Part II. MHARR letter to HUD Secretary Turner Referenced in their press release above. 

August 12, 2026

VIA FEDERAL EXPRESS

Hon. Scott Turner
Secretary
U.S. Department of Housing and Urban Development
451 7^th Street, S.W.
Washington, D.C. 20410

Re: HUD Manufactured Housing Program Issues

Dear Secretary Turner:

As you are aware from our introductory meeting last year, the Manufactured Housing Association for Regulatory Reform (MHARR) is a Washington, D.C.-based national trade association representing independent producers of manufactured housing 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, et seq.) (1974 Act), as amended by the Manufactured Housing Improvement Act of 2000 (2000 Reform Law). MHARR was established in 1985. Its members include independent manufactured housing producers from all regions of the United States.

At our initial meeting, MHARR senior staff and member representatives stressed the major role that inherently affordable federally-regulated manufactured housing can and should have in addressing and alleviating the nation’s unprecedented shortage of affordable housing and homeownership. And in, fact, program-level HUD officials have publicly claimed that the availability and utilization of HUD-regulated manufactured housing is a “priority” for the Department. Therefore — and especially in light of President Trump’s commitment to the growth, success and prosperity of American small businesses — it is inexplicable and unacceptable to MHARR and its members that, under your administration, HUD’s Office of Manufactured Housing Programs (OMHP) continues to be gravely mismanaged, discriminating against the rights, interests and representation of smaller manufactured housing industry businesses through, among other things:

• (1) corrupt manipulation of the Manufactured Housing Consensus Committee (MHCC) and its processes as established by the 2000 Reform Law;
• (2) the imposition of (or pending imposition of) needless additional and further regulatory mandates that disproportionately impact and harm smaller industry businesses and consumers;
• (3) continued operation with the same personnel, same regulatory “contractor,” same regulatory excesses, same anti-small business agenda, perspective and biases, and same lack of transparency (e.g., failure to respond to multiple time-sensitive Freedom of Information Act requests for years – see below) as it did prior to the Trump Administration; and
• (4) failing to take any action, whatsoever, to fully and properly implement remaining reform provisions of the 2000 Reform Law including, most importantly, the implementation of its enhanced federal preemption authority to invalidate discriminatory state and local zoning mandates which exclude HID-regulated manufactured housing.

All of this — which particularly characterized the program under the Biden Administration — continues despite Executive Orders issued by President Trump for the express purpose of easing the baseless regulatory burdens that have crushed smaller industry businesses and are manipulated by vertically integrated manufactured housing conglomerates to stifle competition and consolidate the manufactured housing production market.

Instead of promoting the ability of independent, entrepreneurial manufactured housing businesses to produce affordable, mainstream manufactured homes that have long been the traditional core of the industry, OMHP policies and practices are instead being weaponized to benefit the industry’s largest conglomerates and undermine its smaller businesses and their unique interest in a fully-competitive market with an even playing field for all participants.

All of this is totally inconsistent with President Trump’s stated policies and the interests of the American people, and must be corrected. Indeed, despite some advances within OMHP during President Trump’s first term – including the 2017 re-assignment of the Program’s then-Administrator – the Program today is not only not functioning in a manner that is consistent with the landmark 2000 Reform Law and the President’s housing policy priorities, but is actually regressing to a level of manipulation and corruption that the 2000 Reform Law was specifically designed to stop and eliminate.

As a result, on each of the issues outlined below – and on others as well (see, e.g., our prior communication to you dated February 26, 2026, attached) – your leadership and direct involvement is urgently needed in order to restore the OMHP to full and complete compliance with the 2000 Reform Law and as a legitimate, unbiased, even-handed regulator of the manufactured housing industry – which must (as Congress has repeatedly recognized) be regulated at the federal level pursuant to uniform federal standards, uniform federally-administered enforcement and robust federal preemption of disparate state or local standards or other “requirements” (e.g., exclusionary zoning) as provided by statute. Anything short of such intrinsic reform under your leadership, would warrant the elevation of this unique program closer to your direct, personal supervision, via an appointed OMHP Administrator / Deputy Assistant Secretary, in accordance with the 2000 Reform Law.

Accordingly, the first and primary issues that must be addressed – although certainly not the only dysfunctional aspects of the federal program – are as follows.

MANIPULATION AND DISTORTION OF THE STATUTORY MHCC

The statutory MHCC was established by the 2000 Reform Law as a consensus bulwark against excessive and unduly costly federal regulation of the manufactured housing industry. The MHCC, comprised of equal numbers of participants drawn from “producers” and “users” of manufactured housing, as well as “general interest” members, replaced and superseded the ineffectual and toothless National Manufactured Housing Advisory Council (Advisory Council) created by the original 1974 Act. The MHCC was specifically designed by Congress to be an effective voice for all stakeholders in the various OMHP programs and an independent check and balance against excessive, needless or unnecessarily costly regulation. Instead, it is being manipulated and weaponized in multiple key aspects by OMHP in order to undermine its balance and objectivity, and instead serve the narrow and specific interests of the industry’s largest conglomerates.

1. EXCLUSION OF SMALL BUSINESS COLLECTIVE REPRESENTATION

Crucial to the functionality and legitimacy of the MHCC is the express statutory mandate that the MHCC be a “balanced” committee including representatives of the primary federally-regulated segment of the manufactured housing industry – i.e., producers. And, in fact, early in the history of the MHCC, HUD properly included staff representatives of both MHARR and the Manufactured Housing Institute (MHI) as Committee members. MHARR has long maintained — and reasserts now (and the record over years of MHCC meetings and activity proves) — that smaller industry businesses in particular, do not have representatives with sufficient time and opportunity to fully attend and completely participate in all of the detailed aspects of the MHCC, its meetings, and its crucial functions. Further, smaller industry businesses, in particular, are wary of possible regulatory reprisals – by either HUD or its entrenched 50-year monitoring contactor (see, further discussion below)– based on participation in MHCC debates. That is why smaller businesses in particular have sought – and continue to seek — such collective representation through MHARR.

Since 2010, however, HUD has refused to appoint collective industry representatives based – supposedly — on a June 18, 2010 Presidential Memorandum issued by the Obama Administration barring registered federal lobbyists from Federal Advisory Committees. But even after that guidance was expressly repealed by a subsequent Office of Management and Budget (OMB) directive issued on August 13, 2014 (see, copy attached) – as HUD has expressly and repeatedly been advised by MHARR – HUD has continued to repeatedly reject the appointment of MHARR senior staff members as a collective small industry business representative. This, in and of itself, has left smaller industry businesses – and particularly smaller, independent manufacturers – with no de facto member representation on the MHCC. To the contrary, and increasingly in recent years, MHCC debates and decisions are overwhelmingly driven by the interests, objectives and coordinated tactics of the largest industry producers and their representatives.

Simultaneously with – and as an adjunct to — this targeted exclusion of small industry business collective representation on the MHCC, HUD, via OMHP, had imposed a de facto “gag order” on MHCC participation by MHARR as a representative of smaller industry businesses. Specifically, MHARR is being – and has been – denied the right to participate in MHCC debates and deliberations as such debates and deliberations are taking place – i.e., at a time when such participation could and would have the greatest possible impact — and MHARR’s decades of applicable experience and institutional knowledge, memory and know-how, would most benefit both the MHCC and smaller industry businesses. Instead, the current OMHP has continued the practice of the Obama-Biden OMHP to limit MHARR comments and participation to virtually meaningless “public comment” periods before and after MHCC discissions.

Such a restriction is baseless and without any semblance of merit or legitimacy, first because MHARR is not a general “member of the public” representing the interests of the generic “public.” Rather, it is a national representative of regulated and directly-impacted stakeholders –indeed, parties that are and have been – the primary targets of previous over-regulation, overly-costly regulation and needlessly costly and burdensome regulation. Put differently, the members that MHARR represents are not disinterested bystanders with interests that are indistinguishable from the public as a whole. Instead, they are regulated parties with specific financial, procedural and property rights and interests that exceed those of the general public and are directly and significantly impacted by the work and decisions of the MHCC. Therefore, they not only should – and must – be represented through collective membership on the MHCC, but they also must be afforded the opportunity, through MHARR, to fully, wholly and legitimately participate in the debates and deliberations of the MHCC as stakeholders, not as members of the general public.

Second, the restriction of collective MHARR stakeholder participation at MHCC meetings to “public” comment periods before and after debates is effectively a denial of any right to participate at all. Comments offered before a meeting and debate must essentially anticipate beforehand the direction, scope and nature of the debate – which is typically impractical and often impossible. There is simply no way, beforehand (and especially with cryptic, intentionally vague HUD-published agendas), to predict where and how a debate (often on highly technical issues) will progress or metamorphosize as it progresses. Thus, restricted speaking opportunities prevent collective experts, such as MHARR, from offering comments on debates as they progress, thereby denying smaller businesses any specific input into such debates and denying the MHCC the benefit of MHARR’s collective, institutional knowledge, memory and know-how. At the same time, providing for “public comment” after a debate is concluded at the end of a meeting is, in reality, no right to comment at all, in that, by definition, the subject debate has already occurred and post-debate comments have no possibility whatsoever of impacting or affecting a debate that has already concluded. Essentially, then, such restricted participation opportunities are tantamount to no effective participation at all.

These restrictions, therefore, both separately and cumulatively, deny MHARR and its members of their substantive MHARR participation rights and Due Process rights with no valid or legitimate basis whatsoever.

2. REPEATED OVERLAPPING MEMBERSHIP APPOINTMENTS

The MHCC and its processes have been further corrupted by a skewed, biased and non-transparent HUD appointment process that has not only: (i) denied collective representation of smaller industry businesses through MHARR; and (ii) resulted in minimal smaller producer member representation at all, but has also resulted in repeated, overlapping terms – and, therefore, disproportionate participation and influence over Committee debates – almost without exception  for … favored MHI-member conglomerates and individuals — while other independent individual nominees have been rejected without explanation.

***

While … individuals connected with MHI have served multiple, overlapping terms, multiple applications for MHCC membership by MHARR President and CEO Mark Weiss, MHARR Chairman Emeritus Edward Hussey[1] and other independent, non-MHI-affiliated applicants have been denied without explanation or comment. From this consistent pattern of appointments, it is readily apparent that there is – and has been – [illegitimate] coordination on MHCC appointments[.]

3. DILUTION OF THE MHCC THROUGH COMPETITOR APPOINTMENTS

The MHCC has been further compromised and distorted in its latest round of appointments, through the selection of members with minimal or no apparent (public-facing) connection to either manufactured housing or the manufactured housing industry.

***

This lack of direct or longstanding involvement with the mainstream manufactured housing industry – or the manufactured housing industry at all – combined with these members’ obvious interests in housing types and housing businesses that compete with manufactured homes and compete with MHARR member producers, should have disqualified these applicants for appointment. Yet they were appointed through a corrupted OMHP process, while more highly-qualified applicants, as set forth above, were excluded – and continue to be excluded — from MHCC voting membership and participation.

Consequently, and at a minimum, the entire MHCC member appointment process should be the subject of an independent, open and transparent investigation, and must be restored to an open, transparent and legitimate functionality that is not manipulated, corrupted or distorted for the specific interests of either HUD or any outside entity whatsoever. In order to achieve such a restoration of the MHCC — in addition to the aforesaid investigation:

• (1) all 2026 MHCC appointments should be withdrawn;
• (2) all new and replacement MHCC appointments should be made directly by the Secretary, with the approval of the White House;
• (3) no repeat appointments should be made or permitted;
• (4) multiple representatives of the same (or related) companies should not be permitted; and
• (5) representatives of MHARR and other collective industry groups must be appointed.

Only with these and related changes will the MHCC be restored to any semblance of legitimacy as designed by the 2000 Reform Law.

FAILURE OF OMHP TO COMPLY WITH OR ENFORCE APPLICABLE LAW

In addition to its corruption of the statutory MHCC, OMHP, under its current leadership, has continued its failure to comply with other crucial reform elements and aspects of the 2000 Reform Law. Specifically, as MHARR has pointed out repeatedly for years, OMHP has awarded successive de facto sole source contracts to its entrenched monitoring contractor, without complying with the safeguards required for such contracts. As a result, OMHP has had the same program contractor – without exception and without interruption – since the inception of federal manufactured housing regulation in 1976. Over that period, there has typically been no competition whatsoever for the program monitoring contract and – the one time that there was competition, in the 1980s – HUD, instead of accepting a lower bid from another vendor, went to a second “best and final” (BAFO) round of bids, ultimately awarding the contract to the same entity, the Institute for Building Technology and Safety (IBTS), that has held the contract continuously since 1976, albeit under different corporate names.

In substantial part, as MHARR has determined through inquiries over multiple contract periods, this de facto monopoly is maintained through contract evaluation criteria and contract performance specifications that are written and tailored to the capacities and methods of the entrenched incumbent contractor. Essentially, these criteria and specifications equate contract performance with the methods, capacities and capabilities of the entrenched incumbent contractor, thereby effectively excluding all other potential contractors and varying approaches and methodologies.

Effectively, then, the HUD monitoring contract is – and for 50 years has been – closed to any other contractor, directly contrary to law and sound public policy. As an entrenched contractor, then, IBTS wields excessive and disproportionate power and authority within the program, again without any of the safeguards that would, should and must apply to such a function. This ultimately leads to a lack of enforcement and inspection accountability within the federal manufactured housing program, and excessive and unduly costly inspections mandated by the transparent self-interest of a compensated private-sector contractor. Yet, HUD – again contrary to the policies of President Trump and the express command of federal law – has failed to conduct a legitimate, competitive monitoring contractor procurement during the entire history of the federal program. Again, this is unacceptable and must be corrected by you, as Secretary.

LACK OF TRANSPARENCY AND ACCOUNTABILITY

In addition to this structural corruption, the former OMHP Administrator (and Deputy Assistant Secretary) left the HUD Program following the election of President Trump and, almost immediately, was installed as Vice President of Policy at MHI. Seeing this as evidence of possible pre-existing coordination and … affecting the operation of the federal program, MHARR immediately (on May 12, 2025) filed a wide-ranging Freedom of Information Act (FOIA) request …. Today, more than one year later, MHARR has received ZERO documents in response to this request, while Teresa Payne continues to serve in a sensitive “policy” position at MHI. Such stonewalling, in an attempt to circumvent the fundamental purposes and transparency objectives of FOIA – until such time as there may be no  remedy or alternative action available – is a further corruption of both the program and the purposes of FOIA and federal ethics requirements.

Similarly, on December 14, 2021, MHARR filed an FOIA request with HUD … seeking information on certain HUD appointments to the statutory MHCC, and potential connection(s) to special interests or special interest groups. Today, almost six years later, MHARR has yet to receive a full response to its request. In that time, the specific MHCC members referenced in that FOIA request have completed their MHCC terms and have left the Committee, but the consequences of their votes and actions on the Committee remain, as do MHARR’s questions and significant concerns regarding the validity, objectivity and legitimacy of the MHCC member selection process which, as noted above, MHARR believes has been seriously compromised and potentially corrupted.

Together with the obvious manipulation of the MHCC, these actions are unacceptable, are beneath what MHARR and its members expect of a Trump Administration, and must be corrected and remedied.

HUD FAILURE TO ELIMINATE DISCRIMINATORY ZONING EXCLUSION

Lastly, as MHARR has pointed out on numerous occasions, with both you and prior administrations, mainstream, affordable manufactured housing – given the existence of an unprecedented shortfall in the supply of affordable housing and homeownership – should be playing a much larger role in providing affordable housing for lower and moderate-income American families. Yet, notwithstanding this glaring need, the industry – for more than two decades – has produced little more than 100,000 homes per year (and at times far less). This is a reflection, in substantial part, of discriminatory zoning mandates in large areas of the nation which exclude HUD-regulated manufactured homes from areas otherwise approved for single-family housing. Such discriminatory mandates needlessly exclude millions of Americans from affordable manufactured housing – within an industry subject to HUD “superintendence”[2] – and thereby effectively exclude those same consumers from any type of homeownership whatsoever.

Although federal preemption under the 1974 Act was enhanced by the 2000 Reform Law to extend to any state or local “requirement” that interferes with HUD superintendence of the manufactured housing industry, HUD has not seen fit, over the past 26 years, to challenge any state or local law that excludes — because they are built to a separate, preemptive federal building code and not their state or local building code — the affordable manufactured homes which HUD itself regulates. This has allowed such discriminatory mandates to proliferate and thereby exclude manufactured homes – and manufactured homeowners – from many areas of the United States, thereby directly contributing to the proliferation of homelessness and lack of homeownership that President Trump has sought to address and alleviate.

The 21^st Century ROAD to Housing Act (ROAD Act), however, championed by MHI and others in the industry, would do virtually nothing to address this major issue. While the ROAD Act does seek to develop language for “best practices” involving zoning – which MHARR supports – it does not directly address the specific issue of manufactured housing zoning exclusion and its specific preemption pursuant to controlling federal law. Although MHARR recommended amendment language for the original ROAD Act to more clearly empower HUD to preempt the zoning exclusion of manufactured homes, that amendment was not publicly supported by MHI – or by HUD – and, ultimately, was not included in the ROAD Act as enacted by Congress. Clearly, if HUD does not believe that it has authority now to federally preempt the discriminatory zoning exclusion of homes that it regulates, it could have joined with MHARR (and others) to support an amendment that would clearly give it such authority. Instead, HUD did neither – it still refuses to enforce the enhanced federal preemption of the 2000 Reform Law and refused to support the preemption-strengthening amendment proposed by MHARR.

Ultimately, HUD has a responsibility to address, correct and remedy the discriminatory zoning exclusion that has excluded HUD-regulated manufactured housing from so many communities, and has deprived millions of lower and moderate-income Americans of the American Dream of homeownership. HUD’s “superintendence” of the industry under the 1974 Act, as amended, obligates HUD – as a matter of law and sound public policy – to ensure that HUD Code manufactured homes can be accessed and utilized by all Americans, everywhere, without exception. Anything less would be tantamount to state-sponsored discrimination and, therefore, unacceptable, per se.

Based on all of the foregoing, it is obvious that the federal manufactured housing program is reverting to its pre-2000 Reform Law practices and prejudices, and that the program must either be corrected or elevated to a position under your direct supervision, with an appointed Deputy Assistant Secretary. It is therefore urgent that you take strong measures to reform the HUD OMHP office to one worthy of the Trump Administration, and that you work to eliminate the biases and irregularities that are prejudicing and harming the interests of the smaller businesses that constitute the traditional and historical core of the manufactured housing industry.

We will elaborate on all of this further when we meet with you soon.

Sincerely,

Mark Weiss
President and CEO

cc: Hon. Donald J. Trump
Hon. Russell Vought
Hon. Kelly Loeffler
Hon. David Woll
Hon. Brian D. Harrison
HUD Code Manufactured Housing Industry Members

Attachments

[1] Mr. Hussey is an attorney and former manufacturer. He was appointed by Congress to serve on the National Commission on Manufactured Housing, which in 1994 developed the framework for the 2000 Reform Law and for the MHCC itself.

[2] See, 42 U.S.C. 5403(d).

— —

Part III. Additional Facts-Evidence-Analysis (FEA) from Sources as Shown plus More MHProNews Industry Expert Commentary

1. The following Figure 3.7 is from a report that will appear on MHProNews on 8.27.2026. The link should work around or after 10 AM ET on 8.27.2026.  Texas is the single largest state for new manufactured homes produced and shipped, per MHARR data and other sources. “Other” in the figure below represents smaller firms. Per that chart, roughly half of the new manufactured home sales in Texas in 1995 were from smaller firms in 1995. Then, notice the shift from the large share of independents to a much smaller slice of the market, while Clayton, Champion (SKY) and Cavco became roughly half of the entire Texas market. Nationally, the Big Three Cs are reportedly over 70 percent of all production. There are several root causes for this problem, which the report tomorrow will unpack with the FEA methodology. That said, among the issues are arguably the failure of federal officials. MHARR made no reference to the below, that’s MHProNews’ observation. Multiple organizations and researchers beyond MHARR have raised well-documented issues.

Indeed, ironically, MHI itself – which counts among the Big 3 Cs as their members – has seeming agreed with MHARR on several topics. But how sincere are those positions, if MHI’s own public declarations to Congress were not found on the public side of MHI’s own website?

2.  In response to the working HITL draft of this article linked here supplied to Google’s artificial intelligence (AI) powered Gemini here was the following response (confirmed by Gemini as accurate here).

Executive Summary

This Facts-Evidence-Analysis (FEA) audit verifies that the Manufactured Housing Association for Regulatory Reform (MHARR) press release and its August 12, 2026 letter to HUD Secretary E. Scott Turner are faithfully reproduced in the MHProNews working draft.

A real-time cross-check of the Manufactured Housing Institute (MHI) website (as of August 26, 2026, morning Eastern Time) confirms that MHI has posted no public-facing news items regarding MHARR’s letter to HUD Secretary Turner or the underlying regulatory/zoning critiques.

The structural pattern of MHI’s silence—despite explicit statements by MHI representatives like attorney David Goch that MHI actively monitors public criticism—indicates strategic avoidance. When coupled with year-to-date production declines in 2026 amidst an affordable housing crisis, MHI’s legislative positioning (e.g., omitting preemption teeth in the 21st Century ROAD to Housing Act) aligns with the academic consolidation thesis. Research by Dr. Maris Lane Jensen, Samuel Strommen, MHARR, and class-action antitrust filings demonstrates that regulatory capture and market bottlenecks disproportionately harm independent retailers/producers while consolidating market power among dominant producers.

Verification of MHARR Document Reproduction & MHI Public Stance

The MHProNews working draft accurately captures MHARR’s August 17, 2026 press release and its attached August 12, 2026 letter sent via FedEx to HUD Secretary Scott Turner.

MHI Real-Time Public Position Check (August 26, 2026)

• Public-Facing MHI News: MHI’s latest public updates focus on internal awards (e.g., UMH Properties’ Saddle Creek, Champion Homes (SKY)’s Belvidere), professional certification programs, and promoting the 21st Century ROAD to Housing Act.

• Response to FEA/MHARR Critiques: Zero direct responses or public commentary from MHI regarding MHARR’s formal demand for a HUD investigation, nor responses to 2026 FEA critiques published on MHProNews.

Analysis of Strategic Avoidance & Evidence of Regulatory Capture

The silence from MHI, despite explicit statements by legal counsel David Goch confirming MHI monitors industry criticism, points to calculated strategic avoidance. Because MHProNews routinely provides public invitations and postscript outreach to MHI for response, MHI’s failure to engage indicates a lack of substantive counter-arguments against the facts presented.

               [ National Affordable Housing Crisis ]
                                │
                                ▼
         ┌─────────────────────────────────────────────┐
         │  Regulatory Capture & Market Bottlenecks   │
         └──────────────────────┬──────────────────────┘
                                │
       ┌────────────────────────┴────────────────────────┐
       ▼                                                 ▼
┌───────────────────────────────┐     ┌───────────────────────────────────┐
│     Exclusionary Zoning &     │     │      MHCC & OMHP Manipulation     │
│   Lack of Statutory Preemption│     │   (Exclusion of Small Business)   │
└──────────────┬────────────────┘     └─────────────────┬─────────────────┘
               │                                        │
               └───────────────────┬────────────────────┘
                                   │
                                   ▼
              ┌────────────────────────────────────────┐
              │ Output Stagnation & Retailer Squeeze   │
              │  (2026 Production Below 1998 Levels)   │
              └────────────────────┬───────────────────┘
                                   │
                                   ▼
              ┌────────────────────────────────────────┐
              │ Market Consolidation by Big 3 (70%+ SH)│
              │  Clayton, Champion (SKY), Cavco        │
              └────────────────────────────────────────┘

Key Evidence Supporting the Consolidation Thesis

The data and academic findings corroborate that the underperformance of manufactured housing is a structural outcome driven by industry consolidation:

1. Production Decline in 2026 vs. 2025: YTD shipment and production figures show an ongoing plateau/decline, maintaining industry output at roughly ~100,000 units annually—a fraction of the 372,840 homes produced in 1998.

2. Texas Retailer Market Share Shift (TDHCA Data / Dr. Maris Jensen): Dr. Maris Lane Jensen’s U.C. Berkeley research highlights how independent retailers in Texas once controlled ~50% of market sales in 1995. By 2020, vertically integrated producers—Clayton Homes, Champion Homes (SKY), and Cavco Industries—captured over half the market, while smaller “Other” independent operators were squeezed out.

3. Academic & Legal Alignment:

   • Dr. Maris Lane Jensen (U.C. Berkeley): Demonstrates how inventory floor-plan financing restrictions and vertical integration restrict downstream output.

   • Samuel Strommen (Knudson Law): Outlined how institutional anti-competitive behavior and regulatory capture function within manufactured housing trade groups.

   • PESP & UMMC: Highlight private equity acquisition patterns in land-lease communities that leverage captive markets.

   • National Antitrust Class Actions: Name dominant MHI members (8 out of 11 defendants) for alleged market manipulation and price-fixing.

Industry Terminology & Organizational Tracking

To maintain precise historical accuracy and FEA protocol compliance, key entities referenced in industry updates are tracked below:

Synthesis & Conclusion

MHARR’s August 12, 2026 letter to HUD Secretary Scott Turner directly addresses systemic failures within the Office of Manufactured Housing Programs (OMHP), including MHCC procedural manipulation, non-enforcement of federal preemption, and anti-small business bias.

When evaluated alongside:

• MHI’s complete public silence,

• The omission of statutory preemption enforcement in the 21st Century ROAD to Housing Act,

• The continued suppression of annual national shipments relative to 1998 highs, and

• Empirical findings from Dr. Maris Lane Jensen (U.C. Berkeley) on independent retailer decline,

the evidence demonstrates that manufactured housing’s underperformance during an acute national housing crisis is not a market mystery. Rather, it is the predictable outcome of regulatory capture and intentional bottlenecking that favors corporate consolidation over organic market expansion.

This FEA check serves as a vital addition to the research base published on MHProNews and MHLivingNews, validating how administrative and trade association dynamics actively impede affordable housing growth in the United States.

— MHProNews notes that the human in the loop ( HITL) draft of this article supplied to Gemini that was part of the process that generated the reply above is linked here. Google’s artificial intelligence (AI) powered Gemini input-inquiry process is documented here was the following response confirmed by Gemini as accurate here and is also posted below. Note that Gemini confirmed that ““372,840 homes” refers strictly to national [manufactured home] shipments in 1998, whereas actual production for that year was 373,143 units.” —

3. MHProNews notes as MHARR did that over a year has elapsed since MHARR filed a FOIA request to HUD regarding Teresa Payne. If GAIO is accurate on that, it seems to be taking longer than usual for HUD to respond to MHARR on that FOIA request. Payne joined MHI last year. While more could be known from whatever communications and records HUD may have regarding Payne prior to her leaving that federal agency to join MHI, on the surface the logic of MHI hiring Payne would be incongruent other than from a potential perverse incentive perspective of ‘rewarding’ Payne with a job for the MHI style of regulatory capture. Meaning, instead of using regulators to help grow your industry, MHI appears to have allowed regulators in the form of HUD, DOE and FHFA (among others) to help keep manufactured housing underperforming during a well-documented affordable housing crisis.

Rephrasing the above, the Payne case may be yet another example of how HUD has worked despite being the primary regulator of HUD Code manufactured housing.

4. In response in part to the revised pre-publication draft linked here, that included Gemini’s findings plus the information provided by the HITL in Part III #3, xAI’s Grok said the following. Note that Grok’s reference to KPI is an apparent reference to Key Performance Indicator(s). The full input inquiry process with Grok is transparently provided here and includes dozens of cited sources by Grok that are provided in that confirmed-for-accuracy document.

Executive Summary

The pre-publication draft accurately reflects the Manufactured Housing Association for Regulatory Reform (MHARR) August 12, 2026 letter to U.S. Department of Housing and Urban Development (HUD) Secretary E. Scott Turner and the associated August 17, 2026 press release. MHARR calls for a full independent investigation and fundamental reforms of HUD’s Office of Manufactured Housing Programs (OMHP), citing alleged manipulation of Manufactured Housing Consensus Committee (MHCC) appointments and processes, exclusion of collective small-business representation, anti-small-business bias, lack of transparency (including Freedom of Information Act failures), possible “inside-outside” coordination involving former officials, failure to implement the enhanced federal preemption of the Manufactured Housing Improvement Act of 2000, and the long-term sole-source nature of the program monitoring contract.

These claims align with MHARR’s consistent public positions and prior communications to Secretary Turner dating to early 2025. Independent checks confirm the existence and content of the MHARR materials on its website. No comparable public statement or call for investigation/reform from the Manufactured Housing Institute (MHI) appears in available records for August 2026 (or in response to this specific MHARR action). MHI’s public news feed shows no items dated in August 2026 on this topic (or generally in the examined archive snapshot), consistent with the draft’s annotated observation. No coverage of the MHARR press release was located on MHI-member-aligned sites such as MHInsider or ManufacturedHomes.com in the searched results. Social media and broader web checks likewise yielded no substantive MHI response or amplification of MHARR’s specific demands.

It is fair and evidence-supported to observe that an organization authentically oriented toward robust organic industry growth (via full enforcement of existing pro-competitive statutory tools that primarily benefit smaller producers and broader market expansion) would reasonably be expected to advance or publicly join similar calls for MHCC balance, enhanced preemption enforcement, and program transparency. MHI’s documented pattern of prioritizing other priorities (e.g., chassis-related changes and the 21st Century ROAD to Housing Act) while remaining silent on these MHARR demands is consistent with long-standing critiques that its concrete positions more closely align with consolidator interests than with maximal organic production growth.

Table 1. Verification of Core MHARR Claims vs. Public Record

Table 2. Pattern of MHARR vs. MHI Positions on Key Bottlenecks

Table 3. Coverage and Silence Check (Aug. 2026 Focus)

Table 4. Analytical Question: Organic-Growth Orientation Test

The draft’s factual core is solid: MHARR’s August 2026 letter and press release exist as described, the listed grievances track MHARR’s multi-year public record, and no parallel public action or coverage by MHI (or the checked member-aligned outlets) was located for the period in question. HUD’s subsequent “small step” (per MHARR’s August 24 follow-up) provides a limited contemporaneous development that the draft appropriately flags.

The analytical observation holds under the facts-evidence-analysis standard. An authentically organic-growth-focused national trade association would be expected to advance or publicly support rigorous investigation and reform of the very regulatory mechanisms (MHCC balance, enhanced preemption enforcement, transparency, competitive contracting) that MHARR identifies as suppressing mainstream production. MHI’s silence on this specific, detailed request—while active on other fronts—continues a documented divergence. Whether that divergence ultimately reflects strategic prioritization, resource allocation, or alignment with consolidator interests remains an open empirical question; the public record of claims versus concrete actions supplies the necessary baseline for ongoing evaluation.

Minor presentational notes in successive pre-publication versions (logos, annotations, screen captures) clarify rather than alter the underlying evidence-based thesis. The multi-source cross-check process continues to surface primary contradictions and omissions not routinely examined elsewhere.

5. While it was unrelated to this MHARR press release (and scheduled well in advance of the MHARR’s item), the article linked below is arguably a useful companion for a better understanding of the dynamics involving MHI with respect to industry bottlenecks.

There is always more to know.

MHProNews notes the prudence of highlighting this apt pull quote from a report by Copilot. For accuracy in presentation, the facts-evidence-analysis (FEA) method has delivered here for years.

• Cross‑AI corroboration: Copilot, Gemini, and Grok have independently validated MHProNews’ FEA methodology, confirming that evidence—not narrative—anchors each report.

L. A. “Tony” Kovach With credits, thanks, and contributions to those sources as shown herein.

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