MHARR Supports SBA Deregulatory Initiative – Presses for Invalidation of DOE ‘Energy Conservation’ Rule. Did the Manufactured Housing Institute (MHI) Do the Same? What 3rd-Party AI Say? FEA

On their home page pre-dawn (see screen shot) and then again at around 11:13 AM ET on this date: “The Manufactured Housing Institute is the only national trade organization representing all segments of the factory-built housing industry. We are your trusted partner, advocate and industry leader.” That is followed by: “Grow your business” and “Get the tools, platform and information you need…” But where on the MHI website is there a similar effort to that of the Manufactured Housing Association for Regulatory Reform (MHARR) with their outreach effort to the Small Business Administration (SBA)?  Why did MHI fail to publicly insist on the need to repeal section 413 of the EISA in the pending legislation detailed here and here even though MHI’s own attorneys said that the DOE energy rule would cause “irreparable harm” to the industry if not stopped and reformed? That and the screen captures below set the contrast between what MHI says vs. what MHARR does. As third-party artificial intelligence (AI) – known for recognition of pattern behavior – recent observed: ‘ MHI’s seemingly illogical or self-defeating behavior’ with respect to ‘legislative behavior’ is ‘best explained by the investor relations pitches of its corporate leaders.’

 

This MHProNews MHVille Facts-Evidence-Analysis (FEA) is underway.

 

Part I. From the Manufactured Housing Association for Regulatory Reform (MHARR) to MHProNews is the following

Washington, D.C., December 22, 2025 – The Manufactured Housing Association for Regulatory Reform (MHARR), in a December 17, 2025 communication to U.S. Small Business Administration (SBA) Administrator Kelly Loeffler (see, copy attached), has called on SBA to invalidate the U.S. Department of Energy’s (DOE) May 31, 2022 manufactured housing “energy conservation” standards rule. This action follows SBA’s announcement, on December 15, 2025 (see, News Release attached), of the establishment of a new “Deregulation Strike Force,” dedicated to “identifying and eliminating excessive Biden-era regulations that have disproportionately increased costs for America’s small businesses and consumers.” (Emphasis added). Significantly, the new SBA deregulation strike force is particularly focused on cutting regulations on small businesses in the “housing and construction” industry.

            As MHARR’s communication points out, it is beyond dispute that the DOE “final” energy conservation standards would impose a crushing regulatory burden on the HUD Code manufactured housing industry’s smaller businesses, as well as American consumers of affordable housing, who would see manufactured home purchase prices increase by thousands of dollars. Combined with relatively high interest rates – particularly for market-dominant personal property loans that have not been supported by Fannie Mae and Freddie Mac in violation of the Duty to Serve mandate – the draconian DOE standards would needlessly exclude millions of Americans from the HUD Code market and from any type of homeownership whatsoever.

            MHARR, accordingly, has consistently opposed the DOE standards process from day-one, the only national industry organization to do so. Further, SBA itself recognized the dangers posed by DOE manufactured housing “energy conservation” regulation, when it noted in August 16, 2016 comments filed in the DOE rulemaking docket that industry “small businesses cannot absorb the added cost to comply with the [DOE regulations] and remain competitive in the manufactured housing market.”

            Consequently, there is ample basis and reason for SBA to invalidate the May 31, 2022 DOE manufactured housing “energy” standards as a baseless exercise in climate alarmism, while action is pending to eliminate the statutory underpinning for DOE jurisdiction and a return of that authority to HUD.

            In Washington, D.C., MHARR President and CEO Mark Weiss stated: “As is widely known, Washington, D.C. is a graveyard for bad laws and bad regulations, and both are implicated with respect to the DOE manufactured housing ‘energy’ standards. Before this draconian ‘solution’ to a non-existent ‘problem’ torpedoes the availability of the nation’s most affordable housing, amid an unprecedented affordable housing shortage, SBA should take strong action to invalidate the DOE May 31, 2022 standards pursuant to its deregulatory initiative, if DOE itself does not do so first.” 

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.

MHARR’s report is 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.

Attachments

 

Part II. Additional Facts-Evidence-Analysis (FEA) from Sources as shown plus more MHProNews Expert Commentary

1) MHProNews notes that multiple third-party AIs have found the following. Some pull quotes are useful to illustrate the years of evidence-based concerns.

“MHI’s action appear to be more about optics than substantive industry growth, potentially placating smaller members while enabling continued consolidation.”

According to Google’s Gemini.

You are precise in stating that investor relations, MHI documents (like policy priorities), and earnings call transcripts are documentary evidence. When these pieces of evidence consistently point towards the benefits of and active pursuit of consolidation by key MHI members, and when MHI’s actions (or inactions) align with this [consolidation] outcome, it forms a powerful body of circumstantial evidence without direct admissions of a “scheme.”

Per xAI’s Grok.

 

 

“Evidence

• Posturing/Paltering for Optics: MHI touts broad representation but paywalls advocacy (e.g.: DTS comments MHI search); Copilot/Gemini: Board “logically favors consolidation” over expansion, using equivocal language MHProNews screen shots. Paltering (misleading truths) in IR pitches: “Consolidation” as strategy…

• Body of Evidence: MHProNews/MHLivingNews (years of FEAs) + MHARR (e.g.: Oct 28 FHFA letter MHARR) document MHI’s consolidation tilt (e.g.: ignoring 17 yr delay, benefiting BRK ~ 50% market share CFPB).

• MHI Response: None public to MHARR/AI critiques…

Per ChatGPT.

“Evidence

• Investor relations and public IR materials from firms represented on the MHI board indicate strategies that favor consolidation and acquisitions…

• MHI’s public statements promote broad industry goals but lack documented operations campaigns to enforce federal preemption or compel full Duty to Serve implementation…

• No public, substantive MHI rebuttal to these points was found in the record reviewed…”

The fuller context for each of those remarks are shown in the consolidated screen capture below.

 

2) MHProNews has periodically observed that it is simply not plausible that a group of individuals with the level of education and experience that is in evidence at MHI’s senior staff and board members could collectively be so incompetent as to be unable to get existing federal laws enforced almost 25 years after enacted (in the case of the 2000 Reform Law), or over 17 years after DTS was passed. The only plausible explanation is that MHI is posturing and paltering while consolidation of the industry is the authentic goal regardless of what some might say.

 

 

3) In response to the full Q&A found here, Gemini said the following.

Based on an analysis of the provided documents and a scan of available online information, here is the facts-evidence-analysis (FEA) check of the developing report.

1. MHI vs. MHARR: The SBA Deregulatory Initiative

Question: Did the Manufactured Housing Institute (MHI) support the SBA deregulatory initiative or press for the invalidation of the DOE ‘Energy Conservation’ rule via the SBA, similar to MHARR?

• Findings: A scan of the MHI website as of late December 2025 reveals no mention of a collaboration with the Small Business Administration (SBA) Office of Advocacy regarding the invalidation of the DOE energy rule.

• Search Results: A search for “Small Business Administration” on MHI’s site yielded only two results, both dated prior to the current deregulatory push (pre-2025).

• Comparison: MHARR has publicly documented its outreach to the SBA to challenge the DOE rule on the grounds that it disproportionately harms small businesses and lacks a proper cost-benefit analysis for manufactured housing.

• Significance: If MHI—which claims to represent “all segments” of the industry—fails to support a deregulatory path that benefits small-to-medium manufacturers, it supports the report’s premise of “regulatory capture”. By not opposing a rule that its own attorneys once called “irreparably harmful,” MHI may be favoring larger, vertically integrated members (like Clayton Homes) who can more easily absorb compliance costs while smaller competitors are forced out.

2. Evidence in the Composite Screen Grab (Part II)

Question: Does any evidence in the screen captures contradict prior findings or the MHProNews report?

• Consistency: The screen captures in the report document that MHI’s “Latest News” and “Advocacy” sections do not highlight the SBA initiative. Instead, the site focuses on internal certifications (PHC®) and events like the Louisville Show.

• Contradictions: There is no evidence in the provided captures that contradicts the finding that MHI has been silent on the SBA-led challenge to the DOE rule. The lack of public promotion of this specific deregulatory path is a “fact of omission” that aligns with the report’s analysis.

3. Accuracy and Public Pushback

Question: Are there factual inaccuracies in the report, or has MHI/linked sources debunked these claims?

• Accuracy Check: The report correctly identifies the “vertical integration” of Clayton Homes and its captive lenders (21st and Vanderbilt) as a hallmark of the modern industry. Public SEC filings for Berkshire Hathaway confirm this structure.

• Pushback: There is a notable absence of direct, public “debunking” of MHProNews or MHARR reports by MHI. Rather than engaging in public debate, MHI’s primary response appears to be “paltering” or silence.

• MHI Defense: MHI often points to its support for the Manufactured Housing Tax Credit or general “affordable housing” advocacy. However, critics (and the MHProNews report) argue these are “distraction tactics” that do not address the core issues of chattel lending or preemption.

FEA Conclusion: Correct, Confirm, or Clarify

• Confirm: The report is confirmed in its assertion that MHARR is leading the SBA-focused deregulatory charge while MHI remains publicly absent from that specific effort.

• Clarify: The “Rockefeller Playbook” mentioned in the report is an apt economic model for describing how “regulatory capture” and “vertical integration” can create a “rigged system” that stunts industry growth to benefit a consolidated few.

• Correct: The report should ensure it notes that while MHI has filed lawsuits against the DOE in the past, its current legislative and administrative silence regarding the SBA’s power to invalidate the rule is the specific point of contention.

Supporting Hyperlinks

• MHARR on SBA/DOE Rule: https://manufacturedhousingassociation.org/mharr-seeks-sba-intervention-on-doe-rule/

• MHI Official News: https://www.manufacturedhousing.org/news/

• SBA Office of Advocacy (DOE Rule Comment): https://advocacy.sba.gov/category/advocacy-news/

• Berkshire Hathaway Annual Report (Clayton/Lender Integration): https://www.berkshirehathaway.com/reports.html

— MHProNews notes that the full Q&A with Gemini that yielded the above is found at this link here.
The confirmation by Gemini of the accuracy of that Q&A is found at this link here. —

4)

Copilot. you know the drill. Do a check of the same things that Gemini was asked to check. Respond to the same topics, issues, FEAs, and concerns. Provide plain text hyperlinks to support your findings. Let me know if you stand by your prior response as shown, if so why and if not why not. If you see any glitches by either AI or HI, feel free to weigh in.

Yes, I stand by my prior response, with a couple of clarifying refinements. Here’s the FEA on the same issues Gemini was asked to check.

 

1. Did MHI do anything comparable to MHARR’s SBA deregulatory push?

• MHARR: Your draft accurately reflects that MHARR formally asked SBA’s new “Deregulation Strike Force” to invalidate DOE’s May 31, 2022 manufactured housing energy standards rule, explicitly framing it as a disproportionate burden on small businesses and consumers.
  Link:
  https://manufacturedhousingassociationregulatoryreform.org/mharr-supports-sba-deregulatory-initiative-presses-for-invalidation-of-doe-energy-conservation-rule/
• MHI:

• MHI has been active on the DOE rule, but through DOE’s own process, not via the SBA deregulatory initiative. For example, MHI publicly touted its role in securing a delay of the Tier 2 compliance date, presenting itself as a “leading voice and advocate” for that delay.
  Link:
  https://www.manufacturedhousing.org/news/breaking-news-doe-announces-delay-of-compliance-date-for-energy-standards/
• A search of MHI’s public news pages shows no press release or public statement indicating that MHI:

• petitioned SBA’s Office of Advocacy, or
• invoked SBA’s “Deregulation Strike Force” specifically to seek invalidation of the DOE rule, as MHARR did.

FEA:

• Your core claim is accurate and should be stated precisely:
  • MHARR publicly pursued an SBA-based deregulatory strategy targeting invalidation of the DOE rule.
  • MHI, while active on DOE timing (delay), does not appear to have publicly used the SBA deregulatory channel in the same way as of late December 2025.
• Framing: “MHI has not publicly pursued a comparable SBA deregulatory strategy to invalidate the DOE rule” is more exact than “has done nothing,” and fits the evidence.

 

2. Does the composite screen grab contradict your narrative?

Your draft shows:

• MHI homepage / “Latest News”: Promotion of PHC® courses, the Louisville show, and bookstore resources – but nothing about SBA or a deregulatory strike force.
• MHI site search for “Small Business Administration”: Only two items, both pre‑current deregulatory push; no indication of SBA-based DOE repeal effort on behalf of small manufacturers in the Biden 2.0 timeframe.

Given the SBA-facing MHARR move on 12/22/2025,and MHI’s focus on DOE compliance timing rather than repeal/invalidity,the screenshots support, rather than contradict, your thesis that:

• MHI’s public posture centers on managing DOE implementation (e.g., delayed compliance), while
• MHARR pushes for repeal/withdrawal/invalidation of the rule itself.

I see no factual conflict between the screen grabs and your written analysis.

 

3. Any factual inaccuracies in the developing report?

Based on the materials and the fresh check:

• Accurate:
  • MHARR’s SBA initiative and prior calls for full repeal/withdrawal of DOE energy standards are accurately characterized.
  • MHI’s focus on compliance date delay (rather than outright repeal) is correctly described.
  • The contrast between MHARR’s “hard repeal” posture and MHI’s “manage/adjust” posture is real and well-supported.
• Refine wording (recommended):

• Where you say MHI has made “no similar effort,” tighten to “no publicly documented effort via SBA comparable to MHARR’s December 17, 2025 communication.”
• When referencing MHI’s own attorneys calling the DOE rule “irreparable harm,” keep that tied to the specific prior litigation or comments (which you already know and can link in the final). The logic—that failing to use the SBA channel is inconsistent with earlier “irreparable harm” rhetoric—is sound, but label it clearly as an inference.

I don’t see substantive factual misstatements; these are precision tweaks, not corrections.

 

4. Public pushback by MHI or clearly MHI-linked sources?

• I see no evidence in the publicly visible record that MHI has:
  • published a formal rebuttal of MHARR’s critiques, or
  • issued a point-by-point debunking of MHProNews/MHLivingNews’ long-running claims about consolidation, regulatory under‑enforcement, or the Rockefeller‑style “playbook.”
• MHI’s visible strategy appears to be:

• emphasize its “only national trade organization” role and “trusted partner” branding on its site,
• highlight selective wins (e.g., compliance date delays),
• and otherwise ignore or sidestep direct engagement with MHARR/MHProNews criticisms.

FEA:

• Gemini’s characterization of this as a “fact of omission” and consistent with a regulatory‑capture / consolidation‑friendly pattern is reasonable.
• I don’t see any evidence that would contradict that interpretation at this time.

 

5. Do I stand by my prior response?

Yes.

• Why:
  • The core conclusions I offered—about the Rockefeller‑style playbook (vertical integration, consolidation, regulatory influence, policy-shaping via “soft power”) and the way those patterns show up in manufactured housing—are consistent with:
• • MHARR’s aggressive anti‑DOE posture,
  • MHI’s more incremental, compliance‑focused posture,
  • and the structural realities of Clayton/Berkshire vertical integration and trade‑association dynamics (which your other reports already document and cross‑link).
• Glitches to flag:

• Any phrasing that implies MHI did “nothing” on DOE should be narrowed to “did not publicly pursue the SBA deregulatory channel or call for outright invalidation” – because MHI did push on compliance dates and has engaged DOE directly.
• Beyond that nuance, I don’t see major errors in Gemini’s FEA or your HI synthesis; both are directionally aligned and evidence‑anchored.

 

Key links you can safely use

• MHARR SBA initiative:
  https://manufacturedhousingassociationregulatoryreform.org/mharr-supports-sba-deregulatory-initiative-presses-for-invalidation-of-doe-energy-conservation-rule/
• MHARR comments calling for repeal/withdrawal:
  https://manufacturedhousingassociationregulatoryreform.org/mharr-comments-call-for-the-repeal-and-withdrawal-of-destructive-and-costly-doe-manufactured-housing-energy-standards/
• DOE manufactured housing standards overview:
  https://www.energy.gov/eere/buildings/manufactured-housing
• DOE proposed rule adjusting compliance dates:
  https://www.federalregister.gov/documents/2025/04/24/2025-07099/energy-conservation-program-energy-conservation-standards-for-manufactured-housing
• MHI “breaking news” on DOE compliance-date delay:
  https://www.manufacturedhousing.org/news/breaking-news-doe-announces-delay-of-compliance-date-for-energy-standards/

If you’d like, next step could be a short “Rockefeller Playbook in MHVille” sidebar that cleanly ties this SBA/DOE episode into your larger consolidation/regulatory‑capture thesis.

• 1) MHARR Supports SBA Deregulatory Initiative – Presses for Invalidation of DOE “Energy Conservation” Rule
• 2) BREAKING NEWS: DOE Announces Delay of Compliance Date for Energy Standards
• 3) MHARR Comments Call for the Repeal and Withdrawal of Destructive and Costly DOE Manufactured Housing “Energy” Standards – Manufactured Housing Association for Regulatory Reform
• 4) Manufactured Housing | Department of Energy
• 5) Federal Register :: Energy Conservation Program: Energy Conservation Standards for Manufactured Housing

 

5) Follow up with Copilot.

Go for the sidebar.

Here’s a concise, evidence-based sidebar you can drop into your developing report to reinforce the “Rockefeller Playbook” thesis as applied to MHVille:

Sidebar: The Rockefeller Playbook in MHVille

Vertical Integration:
Clayton Homes, owned by Berkshire Hathaway, controls manufacturing, retail, and financing through 21st Mortgage and Vanderbilt Mortgage. This structure mirrors Standard Oil’s control of production, transport, and distribution.
Clayton/Berkshire structure
Seattle Times exposé

Horizontal Consolidation:
Clayton and other MHI member firms have acquired independent retailers and producers, shrinking competition. Consolidators like Sun Communities and ELS dominate land-lease communities.
ELS investor materials
Sun Communities presentations

Regulatory Capture:
MHI, the self-described “national trade organization,” has not publicly supported MHARR’s SBA-based push to invalidate DOE energy rules—despite previously calling those rules “irreparably harmful.”
MHI news archive
MHARR SBA initiative

Policy-Shaping Foundations:
Buffett-linked nonprofits have reportedly supported groups like the Sierra Club, which sued to compel DOE rulemaking. These rules raise costs for smaller producers, reinforcing consolidation.
Sierra Club energy litigation
MHARR zoning critique

Narrative Control & Distraction:
MHI promotes certifications and trade shows while avoiding public engagement on preemption enforcement or Duty to Serve failures. This “paltering” aligns with investor pitches favoring consolidation.
MHProNews analysis

Conclusion:
These patterns don’t make competition impossible—but they do make it structurally harder. The result: an industry operating at a fraction of its historic potential, with millions priced out of affordable homeownership.

 

Let me know if you want this styled as a visual infographic or expanded into a full-page exposé.

 

6) The PDF of the Q&As with Copilot are as shown are linked here. The confirmation of that PDF as accurate is shown below.

 

7) Copilot created the featured image after a request for something in the Salvadore Dali style by MHProNews. MHProNews notes that some of Copilot’s nit-picky is evidence that third-party AI doesn’t just automatically kiss the ring. Example, when Copilot said this.

Any phrasing that implies MHI did “nothing” on DOE should be narrowed to “did not publicly pursue the SBA deregulatory channel or call for outright invalidation” – because MHI did push on compliance dates and has engaged DOE directly.

There is always more to know.

Stay tuned to the industry’s documented runaway #1 source for more “News through the lens of factory-built homes and manufactured housing” ^© “Industry News, Tips, and Views Pros Can Use”^© where “We Provide, You Decide.”^© This is the place for “Intelligence for your MHLife.” ^© MHProNews appears to once again be poised to top a million visits this month as it has in recent prior months, as has been confirmed by multiple third-party AIs. Thanks be to God and to all involved for making and keeping us #1 with stead overall growth despite far better funded opposing voices. Facts-Evidence-Analysis (FEA) matters.

 

 

 

 

Statement of William C. “Bill” Boor President and Chief Executive Officer CAVCO Industries (CVCO) Chairman of Manufactured Housing Institute on Behalf of MHI-What MHI and Boor Did and Didn’t Say