MHARR Fact Sheets Define Federal Programs Reform Issues

MHARRWashington, D.C., September 14, 2011 – The Manufactured Housing Association for Regulatory Reform (MHARR) has released a complete set of ten Fact Sheets which define specific key reforms of the Manufactured Housing Improvement Act of 2000 that have not been fully and properly implemented by the Department of Housing and Urban Development (HUD), the federal agency which comprehensively regulates the manufactured housing industry.  The Fact Sheets and an accompanying brief history of the federal regulation of manufactured housing, are a signature initiative of new MHARR Chairman John M. Bostick, designed to clear the confusion that has shrouded many of these issues and simultaneously help advance efforts in the 112th Congress – set in motion by the MHARR Board of Directors in November 2010 — to seek intervention and oversight regarding the implementation of these essential reforms and other related matters.  


During the decade-plus that has elapsed since the enactment of the Manufactured Housing Improvement Act of 2000, successive HUD administrations have either ignored or adopted unduly restrictive interpretations of key reforms in the law, designed by Congress to ensure the parity of HUD Code manufactured housing with other types of housing for all purposes and thus complete the transition of manufactured homes from the “trailers” of yesteryear to legitimate housing.  This failure to fully and properly implement the 2000 law, together with the limited availability of both public and private consumer financing for manufactured home purchases, have fueled an unprecedented and sustained industry decline stretching back to 1998.

In order to reverse this decline, which has cost tens of thousands of industry jobs around the nation and represents a staggering loss of affordable housing opportunities for lower and moderate-income American families, HUD’s approach to the 2000 law must change, but ongoing  efforts by the Department, over the years, to justify its extraordinarily restrictive interpretations of the 2000 law, have spawned significant confusion both within and outside the industry regarding the true intent of these reforms and the specific purposes and objectives that Congress sought to achieve in enacting them.

To put an end to this confusion and foster a better understanding of these issues, as an essential element of MHARR’s work to advance the full and proper implementation of the 2000 law – especially its outreach to Congress – and in order to promote the recovery and revitalization of the industry, Chairman Bostick instructed the Association to exhaustively research the history of these reform provisions and the 2000 law as a whole, going back to the original 1990 “Hiler Amendment,” introduced by former Indiana congressman John Hiler, as well as the records of the resulting National Commission on Manufactured Housing (1993-1994), in order to crystallize in simple, straightforward, easy-to-understand one-page Fact Sheets, the intended scope and purpose of these reforms and the ways that HUD has failed to implement them in accordance with the unmistakable objectives of Congress.

Consequently, over the past five months, MHARR has reviewed and has fully re-analyzed — through the lens of the decisions and actions of HUD regulators over the past decade — all of its historical materials related to the development and passage of the 2000 law, and has produced definitive Fact Sheets on: the necessity of an appointed program administrator; the necessity of collective industry representation on the Manufactured Housing Consensus Committee (MHCC); HUD interpretations that have undermined the role and authority of the MHCC; HUD interpretations that have undermined the independence of the MHCC as a consensus forum; HUD’s failure to implement enhanced federal preemption on key matters such as state and local fire sprinkler mandates; HUD’s effort to expand in-plant regulation without complying with the  due process requirements of the 2000 law; HUD’s failure to ensure full and fair competition for the program monitoring contract; HUD’s re-codification of federal installation standards and regulations, as well as the need for congressional scrutiny of HUD’s runaway program budget and the negative impact of HUD’s failure to fully and properly implement key 2000 law reforms on the availability of private and public consumer financing for manufactured home purchases.    


As this work has progressed, MHARR has periodically released some of the Fact Sheets to specific recipients, in support of its efforts to foster a better understanding of the issues implicated by HUD’s non-implementation of key 2000 law reforms.  Now, though, MHARR is releasing, in one package, the complete set of all ten Fact Sheets, as bedrock documentation for all federal program stakeholders to press for changes at HUD to bring about the full and proper implementation of those 2000 law reforms that, in turn, is needed to return the industry to full prosperity.


In Washington, D.C., MHARR Chairman, John Bostick, stated: “We are extremely pleased to be releasing these Fact Sheets today.  Although aspects of the 2000 reform law can be extremely complex, the Fact Sheets explain, in a commonsense down-to-Earth way, where the Department has gone astray from the intent and design of the law and what needs be done to bring the program back to the path set by Congress.  We look forward to working both with the new program leadership at HUD and the 112th Congress 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 producers of federally-regulated manufactured housing.

The History of the Fedral Mamufactured Housing Program and Fedral Regulation
Manufactured housing is affordable housing, historically used primarily by lower and moderate-income families.  In order to maintain that affordability, without the need for government subsidies, manufactured housing construction and safety must be regulated at the federal level.  Federal regulation allows the full cost efficiencies and savings of factory-based construction to be passed to homebuyers by ensuring: (1) federal preemption of state and local standards and regulations, which facilitates interstate commerce and allows manufactured homes to be sited anywhere; (2) uniform and performance-based federal standards; and (3) uniform federal enforcement based on a balance between affordability and full protection of the homeowner.
These unique concepts to ensure affordable home ownership for lower and moderate-income American families were enshrined by Congress in the National Manufactured Housing Construction and Safety Standards Act of 1974.  This law established the basic framework for the current HUD program and most aspects of the federal standards and enforcement system.  At the time the 1974 law was adopted, however, manufactured homes were transitioning from the vehicle-type “trailers” of the Cold War era, to full-fledged housing.  As a result, Congress based the 1974 law on the federal safety law for automobiles, the National Traffic and Motor Vehicle Safety Act of 1966 (NTMVSA), complete with provisions for recalls. 
As manufactured housing progressed and evolved into full-fledged housing, however, all stakeholders in the federal program recognized the need to reform and modernize the original law to recognize and protect manufactured homes as legitimate “housing” at parity, for all purposes, with other types of housing.
Thus, in 2000, after 12 years of congressional hearings, and based upon the recommendations of a congressionally appointed committee of program stakeholders — the National Commission on Manufactured Housing — Congress, by unanimous consent in both houses, enacted the Manufactured Housing Improvement Act of 2000.  This legislation adopted key reforms to the original 1974 law, the full and proper implementation of which would transform manufactured housing from the trailers of yesteryear to the legitimate housing of today. # #

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

Download the 10 MHARR factsheets  below here

MHARRFactsheet1 Appointed Administrator

MHARRFactsheet2 MHCC Collective Representation

MHARRFactsheet3 MHCC Role and Authority-updated june92011

MHARRFactsheet4 MHCC Procedures-updated june92011

MHARRFactsheet5 Preemption rev.

MHARRFactsheet6 Regulatory Expansion rev.

MHARRFactsheet7 Monitoring Contractor

MHARRFactsheet8 Re-codification

MHARRFactsheet9 Budget

MHARRFactsheet10 Finance



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