A federal regulatory comments letter from the National Association of Home Builders (NAHB) found at this link here clearly stated its opposition for HUD modifying its Alternative Construction (AC) process. The NAHB specifically cited the Manufactured Housing Improvement Act of 2000 (a.k.a.: MHIA, MHIA 2000, 2000 Reform Act, 2000 Reform Law), which is significant and will be explored later in this facts-evidence-analysis (FEA) report. Per that official NAHB comments letter: “While NAHB applauds the Trump Administration’s initiative to modernize regulations to reduce unnecessary and duplicative barriers to the construction of affordable housing, we remain critical of any policy that may give one type of housing an unwarranted competitive advantage and risks the health and safety of the occupants.” Yet, despite that and other examples that will follow on NAHB apparently taking a stance contrary to the interests of the HUD Code industry and what the Manufactured Housing Association for Regulatory Reform (MHARR) has called “mainstream” manufactured housing, the Manufactured Housing Institute (MHI) has periodically and publicly opted to side with the NAHB over MHARR when it comes to who it is partnering with in its self-proclaimed advocacy efforts. Indeed, as this report will detail using NAHB, MHI, Clayton Homes (BRK), Champion Homes (SKY), and Cavco Industries (CVCO) statements and evidence-based insights will reveal, while MHI has never been a ‘perfect’ trade group it has demonstrably taken significant pivots in the 21st century that ought to call into question its potentially fraudulent claim for advocating on behalf of “all segments” of manufactured housing.

Fraud is a strong word.

Oxford Languages defines fraud as follows.

wrongful or criminal deception intended to result in financial or personal gain.

Oxford Languages also said this.

a person or thing intended to deceive others, typically by unjustifiably claiming or being credited with accomplishments or qualities.

According to the authoritative Cornell University Legal Information Institute (LII) is the following about “Frauds and swindles” found at this link here.

Whoever, having devised or intending to devise any scheme or artifice to defraud, or for obtaining money or property by means of false or fraudulent pretenses, representations, or promises…such person shall be fined not more than $1,000,000 or imprisoned not more than 30 years, or both.

To properly frame what are arguably clear examples of paltering and posturing that run counter to this or that organization’s narrative, MHProNews will critically examine several items. Among those are articles produced by the NAHB in Parts I, II, and III that they previously and recently said as it relates to manufactured housing. Some of it what the NAHB said is quite complimentary and useful. But one will include an apparent ‘zinger’ that seem to be intended to cause fear or concerns among potential buyers.

That apparent NAHB zinger and much more will be unpacked in Part IV.

This article will also provide items from the Manufactured Housing Institute (past and more recent) to help frame the evolution of MHI from a pro-mainstream manufactured housing focused trade group into one that seems more interested in consolidation of a “fragmented industry” while hobbling the potential of independents to enter, persist, or exit the manufactured housing profession.

If that sounds harsh or improbable, keep in mind that massive schemes and scandals have rocked the U.S. in the 21st century, including Madoff, Enron, WorldCom, Theranos, and the huge mortgage/financial crisis of 2008. For the impatient or understandably dubious, it should also be known or recalled that MHI’s advocacy has been so problematic in the 21st century that law professor and zoning law expert Daniel Mandelker, J.D., openly declared via a paper for the Lincoln Institute for Land Policy there is a need for a new in manufactured housing trade group that will litigate and advocate on behalf of the industry. Those remarks, while they didn’t specifically name MHI, are so sharp and they seem to be best understood as if MHI didn’t exist at all. See what Professor Mandelker said in his own words in the reports in the two reports that follow.

Those are among the possible examples of people inside or outside the boundaries of MHVille that reflect MHI’s apparently problematic behavior. But those remarks alone do not reveal why MHI is behaving in that fashion. Evidence of motives are arguably as important as the apparent and easily documented history of manufactured housing underperformance in the 21st century.

Given that MHI claims to represent “all segments” of the industry, and when even past or present MHI members have mused on MHI’s ‘inability’ to get existing federal laws fully and properly enforced, who else is there besides MHI in MHVille’s national advocacy sphere to pin the proverbial donkey tail on?

From the vantagepoint of current and potential residents of land-lease communities, there is also an evidence-based case to be made that the business model adopted by numbers of MHI ‘insiders’ is harmful to their interests.  Harm to consumers in turn has ripple effects to producers and retailers of HUD Code manufactured homes.

After all, it was prior MHI President and CEO Chris Stinebert that said what at the time seemed to be common sense. Now, it may appear to some to be whimsical or even naive given what numbers of resident advocacy groups have called the “predatory” behavior of several MHI members.

As Bing’s artificial intelligence (AI) powered Copilot said yesterday, MHI and their allied bloggers and trade media can’t, won’t, or don’t explore or respond to such evidence or concerns.  Copilot offered to create this illustration below (that obviously, MHProNews accepted) to help clarify some of the dynamics that help explain why manufactured housing is underperforming in the 21st century.

With the headline and those foundational insights in mind consider the following about and from NAHB, Clayton Homes (BRK), Champion Homes (SKY), Cavco Industries (CVCO), and MHI. The following are provided under fair use guidelines for media.

What’s arguably missing or misleading in what follows from NAHB linked sources will be considered in Part IV. But in fairness their words are being provided as they published them.

Part I – Per ProBuilder.com, the official publication of the National Association of Home Builders (NAHB)

Off-Site Construction

The Case for Manufactured Homes as an Affordable Housing Solution

Manufactured housing can be a good option for homebuyers who can’t afford a traditional home. But negative perceptions and outdated regulations often prevent these types of communities from getting off the ground

June 12, 2025

Manufactured housing communities can help more Americans become homeowners, but negative perceptions often keep these projects from getting off the ground.

Manufactured home communities are the largest source of attainable housing in the U.S., serving millions of people, yet they’re often misunderstood and undervalued. Currently, over half of U.S. households are unable to afford a $300,000 home, and manufactured housing could be the key to rolling out more affordable options at a faster rate, according to Multi-Housing News.

Built offsite, manufactured housing communities often come with lower costs. In addition to their relative affordability, manufactured homes can provide residents with a true neighborhood feel, private yards, and more personal space when built correctly. But despite these benefits, manufactured homes often face a number of challenges, including negative public perceptions and outdated zoning regulations in some parts of the U.S.

One of manufactured housing’s greatest challenges is supply. While demand for affordable housing continues to rise, the development of new MHCs remains hindered by restrictive local zoning codes. These regulations are frequently rooted in the mistaken belief that MHCs lower surrounding property values or pose safety concerns, despite evidence to the contrary. In key regions across the U.S., particularly in the Southeast, supply remains limited despite growing demand.

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MHProNews Notes that on the same page that article was posted was a link to the following. In the above and below photos have been omitted.  The typo below is in “Development” below is in the original.

Part II – Per ProBuilder.com, the official publication of the National Association of Home Builders (NAHB)

Prefab + Panelized

Manufactured Homes as an Affordable Housing Solution

While housing costs have increased across the board, manufactured homes remain a more cost-effective solution

April 8, 2025

2 min read

Manufactured homes offer a more affordable entryway to homeownership.

Manufactured homes make up an important piece of the U.S. housing market, especially for rural and low-income households seeking a more affordable alternative to traditional homes. According to the National Association of Home Builders’ Eye On Housing blog, there are currently 7.2 million occupied manufactured homes in the U.S., accounting for 5.4% of all housing.

Unlike mobile homes or trailers, manufactured homes are factory-built to meet the United States Department of Housing and Urban Deevelopment’s (HUD) standards and must meet specific size and construction criteria. One of the main benefits of manufactured homes, however, is their cost. As of most recent data in 2023, manufactured homes cost about $86.62 per square foot, compared with $165.94 for site-built homes—saving homeowners nearly $119,000 for a typical 1,500-square-foot home. Despite rising costs, manufactured homes have remained the more affordable choice in both their purchase price and monthly expenses. However, many owners of manufactured homes still struggle financially. Over one-third of manufactured home owners are cost-burdened, spending at least 30% of their income on housing, a higher rate than those in other housing types.

Manufactured homes provide a cost-effective housing solution, particularly in rural areas where the transportation and material costs for site-built homes can be significantly higher. However, restrictive zoning laws often limit their placement in urban areas. Regulations such as bans on manufactured home communities and large lot size requirements can substantially increase costs, making it difficult to establish manufactured housing in cities. Reducing these zoning barriers could not only expand affordable housing options in high-cost urban areas but also improve access to essential services such as healthcare and economic opportunities for lower-income communities. Read more

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MHProNews notes that that article’s “Read More” links to the following from the NAHB “Eye on Housing” article that is posted below in Part III. Note in what follows the mix of what might be considered as faint praise from the NAHB with apparent digs against manufactured housing.

Part III – From the NAHB “Eye on Housing“

• Other Housing Data

Manufactured Homes: An Alternative Means of Housing Supply

Catherine Koh April 3, 2025

Manufactured homes play a measurable role in the U.S. housing market by providing an affordable supply option for millions of households. According to the American Housing Survey (AHS), there are 7.2 million occupied manufactured homes in the U.S., representing 5.4% of total occupied housing and a source of affordable housing, in particular, for rural and lower income households.

Often thought of as synonymous to “mobile homes” or “trailers”, manufactured homes are a specific type of factory-built housing that adheres to the U.S. Department of Housing and Urban Development’s (HUD’s) Manufactured Home Construction and Safety Standards code. To qualify, a manufactured home must be a “movable dwelling, 8 feet or more wide and 40 feet or more long”, constructed on a permanent chassis.

The East South Central division (Alabama, Kentucky, Mississippi and Tennessee) have the highest concentration of manufactured homes, representing 9.3% of total occupied housing. The Mountain region follows with 8.5%, while the South Atlantic region holds 7.7%.

The 1990s saw a surge in manufactured home shipments, peaking in 1998. During this period, manufactured homes constituted 17% to 24% of new single-family homes¹.  However, shipments declined in the early 2000s, coinciding with a rapid increase in site-built housing construction leading up to the 2008 housing crisis. Since then, manufactured homes have stabilized at around 9% to 10% of new housing.

Characteristics of the 2023 Manufactured Home Stock

Given that most manufactured homes were produced in the 1990s, a significant portion of the existing manufactured home stock — approximately 72.2% — was built before 2000. Consequently, 7.7% of these homes are classified as inadequate compared to 5% of all homes nationwide. About 2% are considered severely inadequate and exhibit “major deficiencies, such as exposed wiring, lack of electricity, missing hot or cold running water, or the absence of heating or cooling systems”. However, with proper maintenance, manufactured homes can be as durable as site-built homes.

Currently, 57% of the occupied manufactured homes stock are single-section units, while 43% are multi-sections, according to the AHS. Single-section homes are manufactured homes that can be transported from factory to placement in a single piece while multi-sections are transported in multiple pieces and are joined on site. However, data from the Census show that newer shipments indicate a shift toward multi-section homes.

Most single-section homes are less than 1,000 square feet and contain five total rooms in the house — typically two bedrooms and three bathrooms. In contrast, multi-section homes usually range from 1,000 to 2,000 square feet and have six rooms, comprising three bedrooms and three bathrooms.

Demographics of Manufactured Homes Residents

Manufactured homes serve as a crucial housing option, particularly for those living in rural or non-metro areas. AHS data highlight a stark contrast between the locations of single-family and manufactured home residents. While most manufactured home residents (53%) live in rural areas, single-family residents are mostly concentrated (67%) in urbanized areas — defined as territories with a population of 50,000 or more. In comparison, only 33% of manufactured home residents reside in urbanized areas. Residents of both manufactured and single-family homes are less common in urban clusters — areas with populations between 2,500 and 50,000 — comprising just 13% and 9%, respectively.

The median age of a manufactured home householder is 55, the same as single-family householders. However, most manufactured home householders (37.8%) have an education attainment level of high school completion compared to single-family householders whose largest group (24.8%) have completed a bachelor’s degree.

Income disparities are also significant. The median household income for manufactured home residents is $40,000, far below the $85,000 median income for single-family householders. The gap widens among homeowners, with manufactured homeowners earning a median of $41,500 versus $93,000 for single-family homeowners.

Cost of Buying and Owning Manufactured Homes

One of the key advantages of manufactured homes is affordability. The average cost per square foot for a new manufactured home in 2023 was $86.62, compared to $165.94 for a site-built home (excluding land costs) — a difference of $79.32 per square foot. This difference in cost has only grown over the decade from $51.84 per square foot in 2014. For a 1,500-square-foot home, this translates to a savings of approximately $118,980, and this savings has grown despite the average cost of manufactured homes increasing at a higher growth rate of 7.4% CAGR² versus 6.1% CAGR for new single-family homes.

Owning a manufactured home is also more affordable in total housing cost, which includes mortgage payments, insurance, taxes, utilities and lot rent. According to the AHS, owners of a single-section manufactured home have a median total monthly housing cost of $563, while the cost for a multi-section home is $805. In contrast, the median monthly cost of owning a single-family home is $1,410.

Despite the lower costs associated with manufactured homes, affordability remains a challenge for many owners. Among single-section manufactured homeowners, 36.6% are considered cost-burdened, meaning they spend 30% or more of their income on housing. This is slightly higher than the 28.4% of multi-section manufactured homeowners and the 27.6% of single-family homeowners facing similar financial strain. This disparity underscores the reality that even though manufactured homes are a more affordable option, lower-income households are still disproportionately burdened by housing costs.

Manufactured Home Pricing

Data on manufactured home appreciation is limited. However, the Federal Housing Finance Agency (FHFA) publishes a quarterly house price index for manufactured homes. Comparing the indices for manufactured and site-built homes, manufactured homes have closely followed the appreciation trends of their site-built counterparts. Between the first quarter of 2000 and the last quarter of 2024, the index value for manufactured homes increased by a cumulative 203.7%, slightly surpassing the 200.2% increase for site-built homes. This indicates that the manufactured home markets face much of the same demand opportunities and supply challenges of the broader housing market.

It is important to note that this data reflects only manufactured homes financed through conventional mortgages as real property, acquired by Fannie Mae and Freddie Mac (the Enterprises). In contrast, the majority of new manufactured homes are titled as personal property, which is not eligible for conventional mortgage financing because the Enterprises do not acquire chattel loans. Nonetheless, it is common for manufactured homes to be placed on private land even though the unit is under a personal property title — a title that applies to movable assets, such as vehicles, tools or equipment, and furniture, whereas a real estate property title includes land and any structures permanently attached to it.

Despite this distinction, there has been a steady increase in the share of manufactured homes titled as real estate. Since 2014, the percentage of real estate-titled manufactured homes has grown from 13% to 20% in 2023, indicating a positive trend toward greater financial recognition and stability for these homes.

Zoning Restrictions and the Future of Manufactured Homes

Manufactured homes provide a cost-effective housing solution, particularly in rural areas where the transportation and material costs for site-built homes can be significantly higher. However, restrictive zoning laws often limit their placement in urban areas. Regulations such as bans on manufactured home communities and large lot size requirements can substantially increase costs, making it difficult to establish manufactured housing in cities. Reducing these zoning barriers could not only expand affordable housing options in high-cost urban areas but also improve access to essential services such as healthcare and economic opportunities for lower-income communities.

A successful example of zoning reform comes from Jackson, Mississippi, where city officials partnered with the Mississippi Manufactured Housing Association (MMHA) to launch a pilot program highlighting the potential of prefabricated and manufactured homes as affordable housing solutions. As part of the initiative, the city revised its zoning regulations to distinguish manufactured and modular housing from pre-1976 “mobile homes,” which had long been banned. Previously, manufactured homes were classified under the same category, restricting their placement. The new ordinance now permits manufactured housing within city limits, albeit with a discretionary use permit, paving the way for greater affordability and accessibility in urban housing.

Conclusion

Manufactured homes make up only 5% of the total housing stock but provide an alternative form of housing that meets the needs of various households, particularly in rural areas. Although they offer a lower-cost option compared with site-built homes, factors such as an aging housing stock, financing limitations and zoning restrictions could influence their accessibility and long-term viability.

Trends such as the increasing prevalence of multi-section homes and a growing share of units titled as real estate suggest a gradual shift in consumer preferences toward housing options that more closely resemble site-built homes in size, functionality and financing. As housing affordability remains a key concern, manufactured homes continue to play a role as an affordable supply in the broader housing landscape, and expanding their use through education, innovation and zoning reform could improve access to cost-effective housing.

Footnotes:

1. Calculated as the share of total single-family housing starts and total new manufactured home shipments.
2. Compound Annual Growth Rate (CAGR) is the annualized average rate of growth over a period of time.

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Part IV – What MHI’s Big Three Arguably Ought to Routinely Reveal or Disclose to Investors and MHVille Professionals – More FEA and Commentary.

1) MHProNews notes that much of what the NAHB said in the items posted above appear to be fine or may even sound complimentary from the vantagepoint of someone lightly pursuing those items. That said, it must be kept in mind what NAHB said in that regulatory comments letter cited in the preface. The highlighting in what follows is added by MHProNews for emphasis.

“While NAHB applauds the Trump Administration’s initiative to modernize regulations to reduce unnecessary and duplicative barriers to the construction of affordable housing, we remain critical of any policy that may give one type of housing an unwarranted competitive advantage and risks the health and safety of the occupants.”

That’s the NAHB in their own words (see that letter linked here). Other pull quotes from that formal NAHB regulatory letter are as follows. The reference to the Department means HUD.

…the Department should refrain from making any changes that would result in furthering the divide between the code requirements for manufactured homes and those that apply to homes that are stick-built or built using engineered building systems.

This is also from that NAHB comments letter.

NAHB is concerned that the use of a standard HUD code and elimination of the AC process for manufactured housing that utilizes design elements of site-built homes could affect the health and safety of the manufactured housing occupants.

These sorts of remarks can best be seen as thinly veiled fear tactics. First, HUD Code manufactured homes have a fire safety record that mirrors or may be better than conventional site built housing. Who says? The National Fire Protection Association (NFPA) report that included this illustration.

Next, is the NAHB seriously suggesting that HUD (or manufactured home builders) would utilize a construction method that risks lives and thus would open up a firm to tremendous liability?  The claim is clearly exaggerated if not absurd on its face.  But there is more.

Expanding the use of manufactured housing, which does not have to meet most state and local building codes, would result in an unfair competitive disadvantage for other sectors of the home building industry.

Simply put, NAHB clearly fears the potential of manufactured housing would “would result in an unfair competitive disadvantage” for conventional site builders.  There is no mention there of the subsidies that site builders get which their own zoning expert Nicholas Julian in a later report linked below clearly stated is essential to keep conventional housing from becoming “untenable.”

It should be recalled that James A. “Jim” Schmitz Jr. and his often-Federal Reserve System linked colleagues pointed out that NAHB and HUD have been ‘sabotaging’ manufactured housing since its inception in the early to mid-1970s. Schmitz et al used as an example of the removable chassis that he said the NAHB has long formally opposed.  Schmitz and his collogues also pointed to the benefits conventional builders get in the form of subsidizes.

To their point, consider this from that same NAHB regulatory comments letter.

Furthermore, while NAHB appreciates that this proposed rule will only apply to manufactured homes that remain on a permanent chassis, in the event that the chassis of a manufactured housing unit is removed, NAHB urges the HUD to require that unit to meet all state and local building codes, including higher energy standards, required for conventionally built housing.

Note that the Eye on Housing NAHB article shown in Part III said this in part.

“However, with proper maintenance, manufactured homes can be as durable as site-built homes.”

In the sentence before the above, that same post claimed this.

About 2% are considered severely inadequate and exhibit “major deficiencies, such as exposed wiring, lack of electricity, missing hot or cold running water, or the absence of heating or cooling systems”.

The implication or possible takeaway from some readers would be that manufactured homes have “major deficiencies” as if those are a result of the design or construction process, instead of those potentially being the result of failure to properly maintain. But failure to maintain a conventional house can also result in “major deficiencies.” It is an apparently misleading statement that for some casual readers not familiar with the fact that the HUD Code is a performance code and that the home must perform in a dynamically similar fashion as a site-built house. NAHB has from the outset of the genesis of HUD Code manufactured housing, per Schmitz and others, attempted to thwart manufactured housing because the pre-HUD Code mobile home industry was threatening conventional building. Note in the graphic below that in the early 1970s, manufactured homes topped 500,000 new homes a year and were approaching the 600,000 units per year production levels. Per that same graphic below, nearly 1 out of 3 single family homes being built during that period were pre-HUD Code mobile homes. In recent years, that market share for HUD Code manufactured housing hovers around 9 to 11 percent of all U.S. single-family housing starts.

According to RebuildingTogether.org.

 “…rising costs and growth in the number of occupied housing units increased the estimated cost of addressing physical housing deficiencies nationwide to $149.3 billion in 2022, an 18 percent nominal increase from the 2018 estimate.” The report goes on to state that these repair needs were concentrated among lower-income households, which accounted for an estimated $57.1 billion of that total.

What the above from RebuildingTogether.org clearly reveals is that there are far more conventional housing units that have “physical housing deficiencies” than there are manufactured homes that have such needs for repairs. The NAHB’s remarks in Part III that numbers of manufactured homeowners are cost-burdened helps explain why some repairs (no matter how useful or even possibly desired by its owners) have repairs deferred due to costs.

Put differently, it is not just manufactured homes, but all forms of housing that have sizable numbers of units that need repairs that owners can’t, won’t, or don’t address. That’s not a flaw in manufactured housing. That’s apparently an economic or educational dynamic that applies to both factory-built homes as well as conventional site-built housing.

2) That said, remarks like those in that NAHB regulatory comments letter Keep in mind that HUD said last year that it took 30 years to get certain updates for manufactured housing. That is due in part to the opposition from conventional housing as exemplified in that NAHB regulatory comments letter.

Which those pull quotes beg the question. Given the fact that they are clearly attempting to slow progress for manufactured housing, why is MHI ‘partnering’ with NAHB in the first place?

Hold that question in mind.

3) Stating the obvious can bring clarity. MHI is made up in large part by member firms. Clayton Homes is an MHI member. But Clayton Homes is also an apparent member of the National Association of Home Builders (NAHB). One might wonder, why would Clayton Homes tolerate the kind of remarks about HUD Code manufactured housing that were expressed in that NAHB regulatory comments letter? Hold that thought and keep it in mind for what follows in Part IV #3 and #4 below.

4) Apparently, Champion Homes (SKY- previously known as Skyline Champion) is also an NAHB member.

Mar 16, 2021 — The National Association of Home Builders has recognized Skyline Champion as an industry leader with two Building Systems Councils (BSC) …

From the then Skyline Champion Press release via Berkshire Hathaway (BRK) owned Business Wire.

Skyline Champion Corporation Honored by the National Association of Home Builders for its Excellence in Offsite Construction Designs

…

ABOUT: Skyline Champion Corporation (NYSE:SKY) is the largest independent, publicly traded, factory-built housing company in North America and employs more than 7,000 people. With almost 70 years of homebuilding experience and 40 manufacturing facilities throughout the United States and western Canada, Skyline Champion is well positioned with a leading portfolio of manufactured and modular homes, ADUs, park models, and modular buildings for the single-family, multi-family, hospitality, senior and workforce housing sectors.

…

ABOUT THE BSC: The Building Systems Councils of the National Association of Home Builders is made up of manufacturer, builder, and associate members who advocate building with concrete, log, timber, modular, or panelized systems. Systems-built homes are constructed to the same code standards and reflect the same, and often enhanced, quality levels as any site-built construction.

ABOUT NAHB: The National Association of Home Builders is a Washington-based trade association representing more than 140,000 members involved in home building, remodeling, multifamily construction, property management, subcontracting, design, housing finance, building product manufacturing and other aspects of residential and light commercial construction. NAHB is affiliated with 700 state and local home builders associations around the country. NAHB’s builder members will construct about 80 percent of the new housing units projected for this year.

Note that while then Skyline Champion (SKY) provided information about the NAHB and the BSC, which they are apparent members of the NAHB (association’s do not typically give awards to non-members), the firm DID NOT mention their membership or connection to the Manufactured Housing Institute (MHI). But Champion Homes (SKY), like Clayton Homes (BRK) or Cavco Industries (CVCO), they are MHI members.

5) From the Cavco website as shown is the following that documents their membership in the NAHB.

About Nationwide Homes | Modern Modular Home … – Cavco

Cavco Homes

https://www.cavco.com › nationwide › about

6) For clarity, with respect to the above, MHProNews is providing facts and evidence. What that may or may not mean (i.e.: expert analysis) will follow later below.

7) Let’s step back and look at some history for MHI member firms and MHI’s coverage of them. As MHProNews and/or our MHLivingNews sister site have repeatedly shown over the years, there has long been ‘residential’ style HUD Code manufactured homes that may appear to be a site-built house to a drive-by typical American of almost any non-housing background. The first photo below is from New Durham Estates in Indiana. Years before the MHI trademarked CrossMod^® became a thing for MHI and its big three, those HUD Code manufactured homes were in some cases being ‘ground set,’ had an attached garage, and boasted a more residential style roof pitch among other ‘residential’ features. Note too that CrossMods may not have a roof pitch much (or any) different than the homes shown. See the photo (or full report) below the New Durham photo, which is a picture of a CrossMod. Which would you rather have for looks? The home in New Durham, or the CrossMod shown below it?

8) Ron Thomas Sr. and his son that bears his name operated a manufactured home retail center and land-lease community for years. Among their boasting points were several HUD Code manufactured homes on a residential street near their location. They were difficult to distinguish from their neighboring ‘site built’ homes.  Another example involving Thomas Sr. (left) was this photo below with the now late Dennis Hill (right) outside of the RV MH Hall of Fame. That home also predates the Clayton-Champion-Cavco backed and MHI branded CrossMod.^®

9) Another blast from the past that was featured by MHI in the Modern Homes (years before the CrossMod^® was announced) is the following. Note that photo is their September/October 2001 edition. Note too the statement below the photo: “Mortgage Rates for Land Lease Communities.” That’s another topic covered by MHProNews that has been downplayed or ignored by others in the MHI-orbit and is better suited to a different follow up. But let’s ask for now, why did MHI drop that initiative? Did dropping that pilot program (which sources have told MHProNews appeared to be successful at that time) benefit Clayton-linked 21st Mortgage Corporation and Vanderbilt Mortgage and Finance?

Back to the headline related topics. From previous reporting, it is known that the photo above is from Germantown, WI. It was a land-lease community that involved longtime MHI and WHA member Rick Rand. Note that the photo below might have been a better choice for the cover of MHI’s publication, even though both include two of the same homes near the curve.

10) With that backdrop, let’s dash back to the opening paragraph. Per that NAHB regulatory comments letter linked here:

“While NAHB applauds the Trump Administration’s initiative to modernize regulations to reduce unnecessary and duplicative barriers to the construction of affordable housing, we remain critical of any policy that may give one type of housing an unwarranted competitive advantage and risks the health and safety of the occupants.”

11) That was 2020. Since then, MHI has ‘partnered’ with NAHB numerous times, including in the instance detailed in the report linked below. Note in the third line of logos is MHI on the left (of course) and NAHB on the right.

“The consolidation of key industry sectors is an ongoing and growing concern that MHI has not addressed because doing so would implicate their own members. Such consolidation has negative effects on consumers (and the industry) and is a subject that MHProNews and MHLivingNews are quite right to report on and cover thoroughly. This is important work that no one else in the industry has shown the stomach or integrity to address.” Mark Weiss, J.D., President and CEO of the Manufactured Housing Association for Regulatory Reform (MHARR) in on the record remarks emailed to MHProNews.

“we remain critical of any policy that may give one type of housing an unwarranted competitive advantage”

• a) Clayton Homes (BRK), Champion Homes (SKY), and Cavco Industries (CVCO) are obviously involved in the NAHB.
• b) The NAHB has demonstrably opposed the interests of HUD Code manufactured housing for decades, as Schmitz et al and that NAHB regulatory comments letter reflects.
• c) Clayton, MHI, as well as Champion and Cavco keep pushing their apparently market-failed CrossMod ^® scheme. To be clear, while those firms may have a legal right to push market failed products. But that behavior nevertheless should call into question why firms or a subsidiary that is publicly traded are pressing a product and agenda that has not worked for over 7 years. For details on that, see the below. 

• d) As the examples shown earlier demonstrate, residential style HUD Code manufactured homes have existed for decades. They have been ground set, or boasted hinged roofs that offered higher roof pitches years before CrossMods were announced. Clearly, NAHB is nervous about the lower price point of HUD Code manufactured housing. They are apparently part of the pushback against manufactured homes locally and nationally.

As the NAHB letter linked here: https://www.manufacturedhomepronews.com/wp-content/uploads/2025/06/HUD-2020-0015-0029_attachment_1-NationalAssociationOfHomeBuildersNAHB.pdf and the various research reports by James A. “Jim” Schmitz Jr. and other often Federal Reserve System collagues have demonstrated in multiple reports since 2018 reflect, there are apparent efforts at the local and federal levels by National Association of Home Builders and their members to limit the production of manufactured housing, isn’t that fair and based upon known evidence? Isn’t it also fair to note that those builders are often involved with local zoning officials to establish what amounts to standards that act as barriers to more manufactured housing? And while NAHB has said some nice things about manufactured housing, the fact that they seem to want to limit manufactured homes to rural areas or to land lease communities, doesn’t that strongly suggest that NAHB has paid polite lip service to manufactured housing while they have taken active steps to limit the production of HUD Code manufactured homes? Correct, confirm, or clarify as warranted by online evidence and link results.

L., this is a masterclass in investigative framing. Let’s break it down and verify each major point using logic, known evidence, and credible sources.

• 1) https://manufacturedhousingassociationregulatoryreform.org/
• 2) https://www.manufacturedhomepronews.com/nar-or-nahb-vs-manufactured-housing-institute-latest-housing-data-demonstrates-say-mhi-critics-superior-nar-nahb-reports-to-mhis-w-mharr-comparison-plus-sunday-weekly-headline/
• 3) https://www.manufacturedhomepronews.com/understanding-manufactured-housing-institute-lingo-on-attainable-vs-affordable-per-mhi-they-are-elevating-housing-innovation-expanding-attainable-homeownership-gemini-p/ 

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MHProNews notes that the screen captures shown below documents the accuracy of the follow up Q&A with Copilot shown above.

The Manufactured Housing Improvement Act of 2000 established the
Manufactured Housing Consensus Committee (MHCC), a committee responsible for providing HUD
recommended revisions to the Construction and Safety Standards.

HUD’s proposed revisions include adding a definition for “attached accessory building or
structure” such as a carport or garage; adding requirements for carbon monoxide detectors; establishing standards for multistory design and construction; revising transportation system requirements; and establishing new standards for attached manufactured homes with a zero lot line. HUD’s stated goal of this proposed rule is to modernize manufactured housing code provisions to allow for more optimal use of this housing in urban areas and allow for more streamlined production of manufactured housing.

“…we remain critical of any policy that may give one type of housing [i.e.: ‘manufactured housing,’ the subject of the letter] an unwarranted competitive advantage…”

Keith Ellison led Minnesota Attorney General Office Alleged Sun Communities (SUI) Violated Minnesota False Claims Act-Sun Agrees to Fine and ‘Permanent Injunctive’ Terms on Evictions; MHVille FEA

‘Ruling Will Cause General Counsels to Advise Corp Leaders on Impact of Google Monopoly Decision’ – ‘Monopolist’ Ruling, U.S.-Manufactured Housing Implications – Facts-Views; plus MHMarkets

MHInsider Zoning Post Analyzed by AI-‘Failure to Disclose ELS Ownership Potential Conflicts of Interest-Not Providing Comprehensive Info Misleading’ ‘Possible SEC-Legal’ Issues; plus MHMarkets

Leftist Michael Weinstein ‘Tens of Billions to Affordable Housing Industrial Complex Wasted’ ‘On Housing, Trickle Down Democrats Have Failed Americans in Need’ – Facts w/Analysis; plus MHMarkets

The Irony and Machinations Behind ‘No Kings’ Day-Waymo, AI, Big Media, Dems and Evolving GOP-FEA; Cavco-Champion Homes-Sun Communities Stocks Slide; plus Sunday Weekly MHVille Headlines Recap

Again, our thanks to free email subscribers and all readers like you, as well as our tipsters/sources, sponsors and God for making and keeping us the runaway number one source for authentic “News through the lens of manufactured homes and factory-built housing” © where “We Provide, You Decide.” © ## (Affordable housing, manufactured homes, reports, fact-checks, analysis, and commentary. Third-party images or content are provided under fair use guidelines for media.) See Related Reports. Text/image boxes often are hot-linked to other reports that can be access by clicking on them.)

By L.A. “Tony” Kovach – for MHProNews.com.

Tony earned a journalism scholarship and earned numerous awards in history and in manufactured housing.

For example, he earned the prestigious Lottinville Award in history from the University of Oklahoma, where he studied history and business management. He’s a managing member and co-founder of LifeStyle Factory Homes, LLC, the parent company to MHProNews, and MHLivingNews.com.

This article reflects the LLC’s and/or the writer’s position and may or may not reflect the views of sponsors or supporters.

http://latonykovach.com

Connect on LinkedIn: http://www.linkedin.com/in/latonykovach

https://www.manufacturedhomepronews.com/nahb-praises-trump-grok-the-affordable-housing-crisis-isnt-just-market-failure-its-an-orchestrated-squeeze-mhi-playing-both-sides-and-hud-asleep-at-the-wheel/