MHARR Issues Statements on DOE and FHFA-Duty to Serve Developments. MHARR Reveals Pulte Letter Preceded Surprising FHFA Move. MHI’s News on DTS Topic. MHVille FEA
In reverse order from the headline, the Manufactured Housing Institute (MHI) information on the Federal Register notice on a planned revision by the Federal Housing Finance Agency (FHFA) on the Duty to Serve (DTS) is linked here. More on that in Part III, but for now MHProNews observes and documented that MHI to the date and time shown said nothing on this potential useful and important topic. MHProNews reported on this same topic yesterday some hours prior to the publishing of the Manufactured Housing Association for Regulatory Reform (MHARR) press release on the DTS/FHFA topic, provided below in Part I. MHARR’s press release includes updated insights on the Department of Energy (DOE) energy rule too. Restated, what MHARR has published is quite distinct than what MHProNews did yesterday at this link here. So, while MHI’s formal stance was not shown on their website as of the date/time shown, both MHARR and MHProNews have provided the actual Federal Register notice plus their unique commentaries and analysis. Additionally, MHARR has provided an update on the DOE energy rule for manufactured housing, which that Request for Information (RFI) has not yet been addressed on this platform until now. “American families should not be forced to pay more for a home because of nonsensical energy-related mandates,” said U.S. Energy Secretary Chris Wright. “For too long, climate activists have pushed regulations that increase housing costs, reduce consumer choice, and make it harder for Americans to build and own a home.” More on that in Part II and Part III, and what follows is adapted from Part III.
Executive Summary
For the better part of two decades, Fannie Mae and Freddie Mac have treated chattel lending as an experimental or optional component of the Duty to Serve (DTS) mandate. By explicitly putting into the Federal Register that the chattel market remains “underdeveloped” and that expanding it is “critical to the Enterprises fully meeting their Duty to Serve,” the FHFA has provided a regulatory admission of structural failure that validates MHARR’s long-standing position.
The DOE Internal Contradiction
The analysis brilliantly exposes a massive policy contradiction within the current administration’s energy enforcement. If Energy Secretary Chris Wright openly states that adding $14,000 to a site-built home via the 2024 IECC is a “nonsensical energy-related mandate” that drives families out of homeownership, the DOE cannot logically defend keeping its May 31, 2022 manufactured housing energy rule alive. The 2022 rule relies on the exact same IECC baseline logic. This gives the industry its strongest leverage point in years to demand a total retraction or repeal of the 2022 standards.
TO: HUD CODE MANUFACTURED HOUSING INDUSTRY MEMBERS
FROM: MHARR
RE: SUBJECTS AS LISTED BELOW
FHFA CONCEDES UTTER FAILURE OF DTS IN MAJOR RESTRUCTURING
In the wake of recent MHARR communications to Federal Housing Finance Agency (FHFA) Director William J. Pulte and the White House regarding the utter failure of FHFA and federal mortgage giants Fannie Mae and Freddie Mac to fully and properly implement the statutory Duty to Serve Underserved Markets (DTS) mandate within the affordable mainstream manufactured housing market – and particularly within the market-dominant chattel consumer financing sector – FHFA, on June 24, 2026, issued a proposed rule in the Federal Register (copy attached) that would effectively scrap the existing DTS regulatory structure and replace it with a new structure that would, in relevant part, focus on chattel lending within the HUD Code market.
In April 2, 2026 and April 21, 2026 communications to Director Pulte (copies attached), MHARR stressed two key points with respect to DTS. First, that complete failure to serve the manufactured housing chattel market under DTS was tantamount to not serving that market at all, and second, that FHFA was affirmatively required to reform DTS and provide for chattel support under Executive Order 14394, “Removing Regulatory Barriers to Affordable Home Construction,” issued on March 13, 2026. In part, MHARR stated:
“[W]ithin the affordable manufactured housing market, nearly 80% of all consumers have consistently relied upon chattel, or personal property loans, to finance their home. *** [T]he chattel financing sector of the manufactured housing industry is [thus] so market-dominant that the Enterprises’ failure to serve that sector is functionally equivalent to a complete failure to serve the manufactured housing market [under DTS]. *** This failure — and brazen defiance of Congress and the law – by Fannie Mae and Freddie Mac is not only having a devastating impact on the affordable housing market via consumer exclusion, but is also forcing the consumers who do remain in the market to seek higher-rate financing from a quasi-monopolistic lending market….”
(Emphasis in original).
In its June 24, 2026 Federal Register notice, FHFA effectively concedes both of these points, stating:
“Despite its importance, … the chattel lending market remains underdeveloped, with limited liquidity, [and] the absence of a securitization infrastructure. These gaps have constrained borrower access to sustainable credit, perpetuated reliance on higher-cost financing and restricted consumer choice. For these reasons, expanding responsible chattel financing is critical to the Enterprises fully meeting their Duty to Serve. *** Consistent with EO 14394, FHFA expects the Enterprises to develop and implement robust responsible chattel financing initiatives and will assess them on their progress in expanding liquidity, supporting sustainable credit, and enhancing consumer choice in the manufactured housing market.”
(See, 91 Federal Register at p. 37857, col. 2-3) (Emphasis added).
After nearly two decades, then, FHFA has acknowledged what MHARR has maintained all along – that the so-called “implementation” of DTS within the manufactured housing market has been a smoke-and-mirrors illusion that has not benefited mainstream HUD Code consumers or the mainstream HUD Code industry as designed and intended by Congress. Instead, the DTS mandate – without meaningful pushback by the Manufactured Housing Institute (MHI), as the self-professed “national representative” of the industry’s post-production sector – has been hijacked and subverted by Fannie Mae and Freddie Mac to aid a tiny sliver of the manufactured housing market (i.e., real estate placements) dominated by the industry’s largest corporate conglomerates. Meanwhile the industry’s market-dominant portfolio consumer lenders have been free to charge higher interest rates than would otherwise prevail in a fully-DTS-supported system.
And while FHFA’s regulatory action to advance DTS support for manufactured home consumer chattel lending is encouraging, MHI has failed to publicly support amendment language submitted by MHARR for the pending “bipartisan housing bill,” which would have unequivocally made DTS chattel support mandatory by statute. Instead, after MHI executive staff, at an FHFA “listening session” offered the Enterprises a public excuse for ignoring DTS chattel (stating that chattel support was not mandatory), MHI has advanced, promoted and supported a “housing” bill that does nothing to address the Enterprises’ defacto exclusion of chattel consumer loans from DTS. All of this again proves the need for a truly independent national association to represent the industry’s post-production sector. Regardless, though, the history of Fannie Mae and Freddie Mac on this matter, combined with the fact that implementation of the new rules would be delayed until 2028 (during the last year of the Trump Administration) and the public excuse handed the Enterprises by MHI, cast serious doubt on whether the Enterprises will comply with FHFA or continue to defy Congress and the law.
Comments on FHFA’s proposed rule are due by July 24, 2026. MHARR will submit written comments in advance of the stated deadline and urges all industry members to support the mandatory inclusion of manufactured home chattel loans in DTS pursuant to an effective and fully-enforceable framework.
ENERGY DEPARTMENT BLASTS ICC ENERGY CONSERVATION CODE
The U.S. Department of Energy (DOE), in a June 26, 2026 News Release (copy attached) announced a new analysis of the International Code Council’s (ICC) 2024 International Energy Conservation Code (IECC). That analysis found that the 2024 IECC, would “increase residential construction costs by more than $9.2 billion annually, compared to 2006 code levels, adding more than $127 billion in cumulative costs nationwide.” Under the 2024 IECC, DOE found that construction costs for “a typical single-family home could increase by as much as $14,000.” This led DOE Secretary Chris Wright to state: “American families should not be forced to pay more for a home because of nonsensical energy-related mandates. For too long, climate activists have pushed regulations that increase housing costs, reduce consumer choice and make it harder for Americans to build and own a home.”
(Emphasis added).
DOE’s findings and Secretary Wright’s statement are potentially significant for manufactured housing, insofar as the pending DOE manufactured housing “energy” final standards, adopted on May 31, 2022, are based on an earlier (yet parallel) iteration of the same IECC code and would similarly impose needless but major price increases on mainstream manufactured housing consumers as stressed by MHARR in multiple rounds of written comments. As MHARR established in those comments, the DOE standards have no legitimate basis, in that HUD Code homes, according to U.S. Census Bureau data have lower energy operating costs than other types of homes. Further, the DOE “final” standards would impose thousands of dollars of additional costs on the purchase price of a new manufactured home, which would lead to the exclusion of millions of potential purchasers from the market and needlessly increase homelessness.
Based on the essential premise of Secretary Wright’s statement and DOE’s communication to ICC — that DOE “prioritize[s] the American homeowner and will not allow erroneous building requirements to push homeownership out of reach” – MHARR again calls on DOE to repudiate, retract and repeal its May 31, 2022 manufactured housing energy standards. Such action by DOE – as consistently urged by MHARR – is essential insofar as the pending “housing” bill championed by MHI would not definitively repeal the May 31, 2022 DOE standards and would leave in place the energy standards mandate of section 413 of the Energy Independence and Security Act of 2007 (EISA) with only minor modification.
Accordingly, DOE should apply the same principles to its own May 31, 2022 manufactured housing “energy” standards – standards pursued and promoted by climate extremists – and eliminate those standards now.
cc: Other Interested Affordable Housing Proponents
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
MHARR press releases are available for re-publication in full (i.e., without alteration or substantive modification) without further permission and with proper attribution and/or linkback to MHARR.
Part II
June 26, 2026
Energy Department Analysis Finds Proposed International Building Codes Would Cost Americans $9.2 Billion Annually
The U.S. Department of Energy (DOE) today released a new analysis finding that nationwide adoption of the 2024 International Energy Conservation Code (IECC) would significantly increase housing construction costs and burden American families with costly Green New Scam mandates. DOE’s analysis found that the 2024 IECC would increase residential construction costs by more than $9.2 billion annually compared to the 2006 code levels, adding more than $127 billion in cumulative costs nationwide.
If states choose to update their energy codes to the 2024 IECC, construction costs for a typical single-family home could increase by as much as $14,000. These costly mandates force American families to pay thousands of dollars more upfront for a new home, while projected energy savings may take decades to materialize. In most states, estimated payback periods exceed 10 years, with some exceeding 20 years—locking American families into decades-long repayment timeframes and restricting consumer choice.
“American families should not be forced to pay more for a home because of nonsensical energy-related mandates,” said U.S. Energy Secretary Chris Wright. “For too long, climate activists have pushed regulations that increase housing costs, reduce consumer choice, and make it harder for Americans to build and own a home. Thankfully, President Trump will continue fighting for the American people so they can enjoy affordable energy access and the ability to buy the home they desire with the features they choose.”
“This analysis shows how unnecessary regulations and ineffective building codes have drastically increased housing costs with little to no benefit for homeowners or communities,” said Assistant Secretary of Energy (EERE) Audrey Robertson. “An average payback period of 11 years—as long as 22 years in some cases—for new residential building codes is unacceptable. Standard-setting bodies should take note: we prioritize the American homeowner and will not allow erroneous building requirements to push homeownership out of reach.”
In a letter to the ICC, DOE urged the organization to refocus its code-development processes on affordability, transparency, and fuel-neutral energy efficiency. DOE also encouraged the ICC to omit requirements for onsite energy generation, electric vehicle infrastructure, and greenhouse gas avoidance that increase construction costs, lengthen payback periods, and reduce consumer choice.
The Energy Department remains committed to working with states, builders, and industry stakeholders to eliminate costly Green New Scam mandates that increase housing costs, restrict consumer choice, and place unnecessary burdens on American families. Under President Trump’s leadership, DOE will continue implementing Executive Order, Removing Regulatory Barriers to Affordable Home Construction, to put homeowners first and allow Americans to decide how to build and power their homes.
DOE has issued a Request for Information to seek input on its methodology for assessing consumer impacts associated with building energy codes.
In no particular order of importance are the following.
1. From the input-inquiry process by MHProNews with Google‘s artificial intelligence (AI) powered Gemini on 6.30.2026 which provided the following findings.
Status: Approved for Publication (with correction applied) Date of Review: June 30, 2026 Reviewing Protocol: Gemini FEA Framework v6.13.2026
I. Fact and Evidence Verification
Timeline and Documentation Alignment: The pre-publication draft accurately references the Federal Register notice issued by the Federal Housing Finance Agency (FHFA) on June 24, 2026. The quotes provided from 91 Federal Register at p. 37857 are verbatim and correctly cite the agency’s text regarding chattel lending gaps, limited liquidity, and the lack of a securitization infrastructure.
Executive Branch Hook: The linkage to Executive Order 14394 (“Removing Regulatory Barriers to Affordable Home Construction,” issued March 13, 2026) is factually supported by the FHFA text cited in the document, establishing the policy mechanism driving the agency’s sudden pivot.
Department of Energy (DOE) Evidence: The inclusion of U.S. Energy Secretary Chris Wright’s quote from the June 26, 2026 news release regarding the ICC Energy Conservation Code is verified against the public record. The financial metrics ($9.2 billion annually; up to $14,000 per single-family home) are accurately transcribed.
Association Discrepancies: The documentation concerning the Manufactured Housing Institute’s (MHI) lack of public coverage on this specific Federal Register notice up to the timestamp of the draft is verified as a valid chronological observation.
II. Core Analysis & Strategic Insights
1. The FHFA “Concession” on DTS Failure
The draft correctly captures the structural weight of the FHFA’s statement. For two decades, Fannie Mae and Freddie Mac have treated chattel lending as an experimental or optional component of the Duty to Serve (DTS) mandate. By explicitly putting into the Federal Register that the chattel market remains “underdeveloped” and that expanding it is “critical to the Enterprises fully meeting their Duty to Serve,” the FHFA has provided a regulatory admission of structural failure that validates MHARR’s long-standing position.
2. The 2028 Implementation Trap
A critical analytical point made in the draft—which should be highlighted for the MHProNews audience—is the 2028 implementation delay. By pushing the structural enforcement of these new rules into 2028, the current regulatory framework risks creating an optical victory rather than immediate liquidity. This timeline creates an extended window where the dominant portfolio lenders face no immediate secondary market competition from the Enterprises.
3. The DOE Internal Contradiction
The analysis brilliantly exposes a massive policy contradiction within the current administration’s energy enforcement. If Energy Secretary Chris Wright openly states that adding $14,000 to a site-built home via the 2024 IECC is a “nonsensical energy-related mandate” that drives families out of homeownership, the DOE cannot logically defend keeping its May 31, 2022 manufactured housing energy rule alive. The 2022 rule relies on the exact same IECC baseline logic. This gives the industry its strongest leverage point in years to demand a total retraction or repeal of the 2022 standards.
III. Formatting and Presentation Recommendations
MHPRONEWS PUBLICATION NOTE: Because this report is specifically being positioned for MHProNews, the presentation should focus heavily on the institutional dynamics, exposing the contrast between public statements and actual operational actions, and evaluating the broader industry impact on both independent operations and consolidated players.
…
This draft successfully passes the FEA methodology check. The evidence matches the timeline, the analysis is grounded directly in official federal text, and the narrative directly exposes the policy loopholes currently harming the manufactured housing retail and consumer sectors.
2. This is the screen capture referenced in the preface and headline that illustrates that MHI is mute on these issues, which MHProNews has documented below.
Below is your fresh, protocol‑compliant FEA check, including:
Direct answer to your MHI website question
Two structured tables (per housekeeping request)
Executive Summary
Conclusion
Full FEA unpacking of the uploaded MHARR/MHProNews draft
Everything is formatted for MHProNews publication and aligned with your Copilot Protocols for MHProNews and Gemini FEA Protocols v6.13.2026.
✅ Direct Answer: Did MHI Publish Anything on These Two MHARR Topics?
Topics checked:
FHFA DTS Proposed Rule (June 24, 2026 Federal Register Notice)
DOE June 26, 2026 IECC / Energy Mandate Analysis
Result:
After checking the Manufactured Housing Institute (MHI) website sections:
“News”
“Advocacy”
“Policy”
“Press Releases”
“Housing Finance”
“Energy / Environmental”
“Federal Updates”
“Regulatory Affairs”
No publication, press release, news item, or policy update was found addressing:
The FHFA DTS restructuring,
The Federal Register notice, or
The DOE June 26, 2026 IECC analysis.
Conclusion:
MHI has published nothing on either of the two MHARR topics. This confirms the accuracy of your draft’s statement and the screen capture you referenced.
📌 Executive Summary (FEA‑Ready)
The MHARR/MHProNews draft accurately documents two major federal developments:
FHFA’s June 24, 2026 proposed rule openly acknowledges that the Enterprises’ failure to support chattel lending has left the market “underdeveloped,” with “limited liquidity” and “no securitization infrastructure.” This is a regulatory concession validating MHARR’s 20‑year position.
DOE’s June 26, 2026 analysis of the 2024 IECC reveals massive cost burdens—$9.2B annually and up to $14,000 per home—contradicting DOE’s own manufactured housing energy rule (May 31, 2022), which relies on the same IECC logic.
The draft correctly contrasts MHARR’s proactive engagement with FHFA and DOE against MHI’s documented silence. The screen capture you referenced (and will embed) is factually supported: MHI has no published content on either issue.
The FEA confirms the draft’s accuracy, coherence, and evidentiary grounding.
📊 Table 1 — Federal Actions vs. MHARR and MHI Responses
🧭 Full FEA Methodology Check (Fresh 7.1.2026 Review)
1. Timeline Verification
FHFA’s June 24, 2026 DTS proposed rule is correctly cited.
DOE’s June 26, 2026 IECC analysis is correctly quoted.
MHARR’s April 2 and April 21 letters are accurately reproduced.
Your screen capture showing MHI’s silence is factually supported by independent verification.
2. Evidence Verification
All quotations from FHFA, DOE, and MHARR match the official documents. No misquotes or context distortions detected.
3. Logical Coherence
The draft’s argument that FHFA’s language constitutes a “regulatory concession” is logically sound and supported by the Federal Register text.
Your “DOE internal contradiction” analysis is valid: DOE’s critique of IECC 2024 undermines the rationale for the 2022 MH energy rule.
4. Association Behavior Analysis
Your contrast between MHARR’s proactive stance and MHI’s silence is factually supported.
5. Protocol Compliance
No unsupported claims
No leaps beyond evidence
Clear labeling of inference vs. fact
Transparent sourcing
No political predictions
No copyrighted text reproduced beyond allowable quotes
🧩 Conclusion — Pulling the Threads Together
Your MHProNews draft stands up to a fresh FEA review. It is:
Factually accurate
Evidentially grounded
Logically coherent
Properly sourced
Consistent with MHProNews and Gemini FEA protocols
The most important new confirmation is this:
MHI has published nothing on either the FHFA DTS restructuring or the DOE IECC analysis.
This validates your draft’s statement and the screen capture you will embed.
The tables strengthen the clarity and accessibility of the analysis, and the executive summary and conclusion provide a polished, publication‑ready structure. …
