Attached for your review and information is a July 19, 2012 letter to HUD Assistant Secretary for Housing-Federal Housing Commissioner Carol Galante (the HUD appointed official with direct responsibility for the federal program in the absence of a non-career program administrator as required by law but denied by HUD). With this communication, MHARR is renewing and intensifying pressure for the resolution of specific issues relating to the full and proper implementation of the Manufactured Housing Improvement Act of 2000 (Title VI) which directly impact the financial well-being of the industry’s smaller businesses and consumers of affordable housing.
Because HUD’s failure to fully and properly implement key reform provisions of the 2000 law is no longer debatable, given the evidence presented by MHARR at the February 2012 congressional oversight hearing, the focus of MHARR activity has shifted back to: (1) exposing the actions of federal regulators (or inaction in certain cases) that has created a sharply (and costly) uneven playing field for the industry’s smaller businesses; and (2) renewed pressure for full compliance with the law on specific program issues. Such ongoing MHARR exposure and documentation of the Title VI shortcomings of federal regulators has already produced positive results in connection with activities including the resumption of MHCC Administering Organization funding as announced on July 24, 2012, the federal program’s budget and appropriations requests, the pending Government Accountability Office (GAO) investigation of the HUD program, education in advance of the 2012 presidential election, engagement with the Department of Energy (DOE) and the soon-to-be triggered MHARR legal initiative, among others.
This Title VI activity, in conjunction with MHARR’s aggressive engagement regarding public and private consumer financing, is focused on highlighting the discrimination and exclusionary policies that the industry’s small businesses and consumers face in the nation’s capital which, if not addressed and resolved, threaten to reduce the industry to just a couple of corporate conglomerates, without the healthy competition that has historically characterized the industry and benefitted consumers of affordable housing. Some of these recent discriminatory actions and policies — which the industry should not accept – will be the subject of a series of MHARR White Papers and communications, to be published before the November 2012 elections.
MHARR will continue to keep you apprised concerning all these issues in advance of the Association’s November 2012 Board of Directors meeting.
2012 letter to HUD Assistant Secretary for Housing-Federal Housing-pdf
Manufactured Housing Association for Regulatory Reform
