NAR-‘All Eyes on Texas.’ ‘Manufactured Home Resistance Rooted in Outdates Stigma.’ GAIO Compared NAR Report and Research with Texas MHA and Manufactured Housing Institute on SB785 Results-FEA

“Texas Is Opening the Door to Cheaper Homes. Some Cities Are Barely Cracking It.” “The resistance is rooted in part in an outdated stigma.” So wrote Allaire Conte for the National Association of Realtors (NAR) linked Realtor.com on 8.29.2026 in an article about the recently enacted manufactured home legislation supported by the Texas Manufactured Housing Association (TMHA). Conte observed that “research suggests that a new manufactured home installed on a foundation can cost roughly 35% to 73% as much as comparable site-built construction.” She also stated: “But despite the clear need and demand for wider adoption, manufactured housing has run headlong into a patchwork of local rules that can make them legal in one community, discretionary in the next, and outright impossible in another. And while SB785 is designed to close that gap, it’s also where the limits of the law are already beginning to show.” “Allaire Conte is a senior advice writer covering real estate and personal finance trends. She previously served as deputy editor of home services at CNN Underscored Money and was a lead writer at Orchard, where she simplified complex real estate topics for everyday readers. She holds an MFA in Nonfiction Writing from Columbia University and a BFA in Writing, Literature, and Publishing from Emerson College. When she’s not writing about homeownership hurdles and housing market shifts, she’s biking around Brooklyn or baking cakes for her friends.” So, says about Conte’s bio in brief linked here.

According to GAIO:

“A review of the Texas Manufactured Housing Association (TMHA) “Latest News” feed reveals that even at the state level, there is no consumer-facing or comprehensive public rollout of SB 785 akin to NAR’s analytical coverage.”

“The lack of public educational campaigns on “enhanced preemption” by the Manufactured Housing Institute (MHI) is not merely a passive “division of labor.” Rather, it aligns with a documented consolidation thesis advanced by industry analysts, university researchers, and legal scholars.”

Before peering more deeply into what GAIO had to say, it is appropriate that more detailed insights from NAR’s Conte be provided (see Part I).

This MHProNews MHVille facts-evidence-analysis (FEA) is underway.

 

 

Part I. From Realtor.com by NAR writer Allaire Conte linked here and provided under fair use guidelines for media. Where an ellipsis (…) is shown some content was edited out. Yellow highlighting was added by MHProNews.

Texas Is Opening the Door to Cheaper Homes. Some Cities Are Barely Cracking It.

By Allaire Conte | August 29, 2026

When Millard’s Apple Park was platted in Nacogdoches, TX, in 2002, the 69-lot subdivision was designed to accommodate both traditional houses and manufactured homes.

But only two years later, the city stopped allowing new manufactured homes by right in its residential districts. Homes already there could remain, but they became legally nonconforming—limiting owners’ ability to replace or expand them.

It’s a common pattern across the state: 33% of cities don’t explicitly allow manufactured housing and an additional 11% subject it to a special permit or public hearing, according to a recent analysis from the National Zoning Atlas.

Nacogdoches, for its part, understood the trade-off at the time. Its 2003 comprehensive plan called manufactured housing “one of the most affordable means of entering into homeownership,” but seemed to put more stock in the concerns from local residents about its potential effect on neighboring property values.

Then, in early August, Nacogdoches reversed course.

The City Council unanimously created a new residential district where manufactured homes are permitted by right—including all 69 lots of Millard’s Apple Park.

It was a win for affordability advocates, and especially for owners of the manufactured houses that had been built before the laws changed.

“They don’t have to wait till it just completely falls apart to replace it,” Mike Neu, the city’s executive director of development and infrastructure, told council members. “This gives them options. They didn’t have that before.”

But Nacogdoches was not acting entirely by choice. Beginning on Sept. 1, a new state law (Senate Bill 785) requires Texas municipalities with zoning to allow new HUD-code manufactured homes by right in at least one residential district.

The change will require nearly 400 cities to update their codes to comply, according to an estimate from the Texas Manufactured Housing Association—making Nacogdoches an early glimpse at what could soon play out across the state.

Why Texas is betting on manufactured housing

The city offers a clear case for why state lawmakers are betting on manufactured housing to deliver mass affordability.

… But buying [in Nacogdoches] remains badly mismatched with what local residents earn.

The median home was listed for about $325,500 in August, according to data from Realtor.com®, while the median household income of $39,281 is roughly half of what someone would need to qualify for a mortgage that size. As a result, fewer than 4 in 10 households own their homes.

Renting doesn’t offer residents much relief, either. City officials have described the rental market as “tight,” while Realtor.com data shows the median asking rent reached $962 in August—up 13% in three years.

Manufactured housing, meanwhile, could offer a much lower entry price. A new single-section manufactured home sold for an average of $87,300 in 2025, while a multisection home averaged $151,500.

Those figures exclude land and taxes, so they don’t offer a perfect comparison to a site-built home. But further research suggests that a new manufactured home installed on a foundation can cost roughly 35% to 73% as much as comparable site-built construction.

Texas has already adopted manufactured housing at an enormous scale…The state received 17,458 manufactured homes in 2025, more than 2.5 times the number sent to second-place Florida.

But despite the clear need and demand for wider adoption, manufactured housing has run headlong into a patchwork of local rules that can make them legal in one community, discretionary in the next, and outright impossible in another.

And while SB785 is designed to close that gap, it’s also where the limits of the law are already beginning to show.

Cities can still keep the door mostly closed

While an earlier version of the legislation required cities to allow manufactured homes across a “substantial area of land” and prohibited other regulations that directly or indirectly amounted to a citywide ban, neither provision survived intact.

The final law requires only that the qualifying district apply to “an area of land,” without quantifying how much.

In Nacogdoches, city planners identified three areas that could potentially receive its new R-3M manufactured-home zoning. But only Millard’s Apple Park was actually rezoned. For the changes to span more widely, property owners would have to request the change themselves.

“Theoretically, there could be no other property owners requesting a change to R-3M beyond tonight,” Neu told council members in May.

That means Apple Park’s 69 lots could conceivably represent the full extent of the city’s response—a drop in the bucket compared to the 1,300 units the city needs in the next five years to adequately address demand.

Bellmead, a small city outside Waco, offers an even sharper example. The city created a new manufactured-housing district but requires a tract to contain 5 contiguous acres before it can be rezoned into it.

For Amber Haliburton, that was the difference between building new housing on her family’s property or moving on.

“Because we have chosen a manufactured home, there is currently no clear or practical path for us to move forward in Bellmead,” she told the City Council in February.

Haliburton also questioned why a rule ostensibly intended to open the city to manufactured housing seemed better suited to developers assembling subdivisions than someone trying to place a single home.

City staff acknowledged some of that tension. The new district, Community Development director Fred Morris said, was intended to comply with state law and facilitate development projects, “not to address individual residential lots.”

Bellmead eventually identified a 13.98-acre tract beside an existing manufactured-home development as appropriate for the new zoning. But even that didn’t automatically open the land to manufactured homes. The city’s own memo emphasized that the designation “does NOT rezone the property.” Its owner still has to request the change.

The NZA analysis warned about that possibility before SB785 was passed. Researchers recommended requiring cities to rezone in “good faith,” noting that a municipality could otherwise satisfy the law with land unlikely ever to host a manufactured home.

All eyes will be on Texas

…

By September 2025, the Pew Charitable Trusts had identified nine states that had enacted zoning reforms designed to expand manufactured housing. Some have gone further than Texas, requiring qualifying manufactured homes across single-family residential zones rather than guaranteeing them a foothold in only one district.

At the same time, Washington is attacking other pieces of the problem.

The bipartisan 21st Century Road to Housing Act, which became law in July, includes a series of reforms intended to expand manufactured and modular housing. But it stops short of overriding local zoning, leaving opponents with a powerful tool to continue to limit where manufactured homes can be built.

The resistance is rooted in part in an outdated stigma. Manufactured homes have long been treated as a lesser form of homeownership—cheaper to buy, but also assumed to be a worse investment.

The numbers tell a different story. Realtor.com research found that manufactured homes sold with land appreciated 70.1% from 2019 to early 2026, compared with 58.6% for single-family homes. Even manufactured homes sold without land appreciated 51.6%.

— —

Part II. From the input-inquiry to Google‘s Artificial Intelligence Overview (GAIO) linked here was the following revised response. The full Q&A with linked and screen captured for documented accuracy result is linked here. Note the term “enhanced preemption” is briefly described here.

 

An analysis of the updated context confirms that the original response was mistaken in its characterization of TMHA’s active public rollouts and missed the core systemic explanation for MHI’s silence: the consolidation thesis.

A review of the Texas Manufactured Housing Association (TMHA) “Latest News” feed reveals that even at the state level, there is no consumer-facing or comprehensive public rollout of SB 785 akin to NAR’s analytical coverage. Instead, the law is buried as a static menu item (“SB 785”) under an advocacy tab reserved for registered industry members.

The lack of public educational campaigns on “enhanced preemption” by the Manufactured Housing Institute (MHI) is not merely a passive “division of labor.” Rather, it aligns with a documented consolidation thesis advanced by industry analysts, university researchers, and legal scholars.

The Systemic Context: The MHI Consolidation Thesis

The lack of MHI advocacy for federal zoning preemption and chattel lending laws is viewed by critics as a strategic choice that benefits dominant industry consolidators by intentionally suppressing production.

1. Artificial High Placement Barriers Benefit Portfolio Owners

• The Legal Tool: The Manufactured Housing Improvement Act of 2000 (MHIA) grants federal “enhanced preemption” to override exclusionary local zoning.
• The Posture: MHI has consistently refused to pursue litigation to enforce this preemption, providing what critics call “lip service” advocacy.
• The Consolidation Angle: Keeping placement barriers high limits the development of new land and independent subdivisions. This directly protects the existing portfolios of large, vertically integrated community operators (who are dominant MHI members) by making space scarce and driving up the value of their existing plots.

2. Suppressed Chattel Lending Starves Independent Competitors

• The Legal Tool: The Housing and Economic Recovery Act of 2008 (HERA) includes a “Duty to Serve” (DTS) mandate requiring Fannie Mae and Freddie Mac to support chattel (personal property) loans.
• The Posture: Chattel buyers face an astronomical 65.6% loan denial rate and inflated interest rates (averaging 9.24%), yet MHI has initiated no legal action against federal regulators to enforce DTS.
• The Consolidation Angle: Independent retail lots and smaller manufacturers depend on competitive consumer financing to survive. By allowing the “financing gap” to persist, MHI effectively starves smaller businesses of volume. Deep-pocketed consolidators with captive finance companies step in to absorb the market share, using the restricted supply to maintain higher profit margins.

3. Suppressing Industry Image and Education Campaigns

• Internal Resistance: Internal MHI documents and tipsters reveal that senior staff actively derailed efforts to launch a national public relations campaign modeled after the RV industry’s highly successful “GoRVing” initiative.
• The Outcome: While RV production outpaced manufactured housing by 3.69 to 1 between 2001 and 2024, manufactured home production chronically underperformed, leading to an estimated 6.1+ million “missing” homes relative to late-1990s capacities. This underproduction ensures that demand heavily outstrips supply, further favoring large consolidators who acquire distressed smaller assets.

4. Alignment of Legal, Academic, and Anti-Trust Critiques

• Legal and Academic Scrutiny: Legal analysis by Samuel Strommen (formerly of Blackstone Law) and university-level research by Maris Jensen have independent weight alongside trade watchdogs like MHProNews and MHARR. Their work outlines how MHI functions primarily as a shield for its dominant, consolidating members rather than as a traditional trade promotion group.
• Antitrust Action: These systemic failures have culminated in a sweeping national class-action antitrust lawsuit involving 11 major industry defendants—eight of whom are prominent MHI members.

If you want to look into this closer, would you like to:

• Review the specific legal arguments Samuel Strommen used to connect MHI’s inaction to antitrust violations?
• Deep-dive into the data regarding the “financing gap” and how captive lenders profit from the lack of federal program implementation?

https://share.google/aimode/wWuesGNDl2eSnRjY5

— MHProNews screen captured and provided Google’s share link to both the original and revised response by GAIO here.  —

Part III. Additional Facts-Evidence-Analysis (FEA) from Sources as Shown plus More MHProNews Expert Commentary

In no particular order of importance are the following insights.

1. In response to the developing draft linked here provided to Google‘s artificial intelligence (AI) powered Gemini said the following (screen captures are included for documenting the accuracy of this input-inquiry-response thread is linked here).

Executive Summary

An analysis of the factual record, state and federal statutory text, academic literature, and trade media data confirms that state-level zoning reform efforts—such as Texas Senate Bill 785—have yielded minimal tangible impact on nationwide HUD-code manufactured home production. Industry benchmarks established by Justin “Scott” Susin, Mark Weiss, J.D. (President & CEO of MHARR), and L. A. “Tony” Kovach demonstrate that local municipal loopholes, continuous zoning carve-outs, and a lack of aggressive federal preemption enforcement keep total manufactured housing production operating at a fraction of its historical peak.

While mainstream real estate outlets like the National Association of Realtors (NAR) highlighting state-level zoning challenges is useful, these analyses consistently overlook the statutory authority of federal “enhanced preemption” under the Manufactured Housing Improvement Act of 2000 (MHIA). The systemic failure by dominant industry trade representation—specifically the Manufactured Housing Institute (MHI) and state surrogates like the Texas Manufactured Housing Association (TMHA)—to litigate or enforce federal preemption aligns directly with the documented “consolidation thesis”. Rather than expanding independent market access, MHI’s strategic posture maintains artificial barriers to entry, benefiting vertically integrated producers and community portfolio consolidators.

Facts-Evidence-Analysis (FEA) Synthesis

1. Baseline Key Performance Indicators & State-Level Limits

• Production Stagnation: Despite a national affordable housing crisis, national manufactured home production for 2026 remains on track to trail 2024 and 2025 levels, operating at approximately 25%–30% of the 1998 highwater mark (372,840 units).

• State vs. Federal Preemption Limits: As observed by Scott Susin and Mark Weiss, state legislation like Texas SB 785 allows municipalities to create narrow, restrictive “districts by right” (e.g., Nacogdoches rezoning only a single 69-lot subdivision or Bellmead requiring 5 contiguous acres), rendering the net production gain minimal.

• The NAR / Realtor.com Omission: While NAR’s analysis accurately highlights local zoning resistance and price disparities, it ignores the federal “enhanced preemption” explicit in the MHIA of 2000. Federally regulated HUD-code homes legally bypass conflicting local municipal construction and placement standards when federal preemption is actively enforced.

2. The Consolidation Thesis & Strategic Avoidance

• Silence on Federal Preemption & DTS: Neither MHI nor TMHA maintains aggressive public or legal campaigns to enforce MHIA enhanced preemption or HERA Duty to Serve (DTS) chattel loan support.

• Protection of Portfolio Holders: Restricting new independent land developments preserves artificially low supply, driving up the valuation of existing land-lease portfolios owned by major MHI corporate leaders.

• Suppression of Independent Competitors: High loan denial rates on chattel loans (65.6%) starve independent retailers and smaller builders of volume, enabling deep-pocketed consolidators with captive finance arms to acquire distressed assets.

3. AI Baseline Logic & The Google AI Overview (GAIO) Shift

• Initial Surface Interpretation: AI engines (like GAIO) initially accept corporate messaging at face value, viewing state-level legislative attempts like SB 785 as proactive advocacy.

• Correction via KPI & Primary Evidence: When pushed with hard Key Performance Indicators (KPIs), primary source legal documents, and secondary data (e.g., Samuel Strommen’s antitrust analysis, Maris Jensen’s academic research, and MHARR/MHProNews reporting), initial AI logic collapses. The revised GAIO output explicitly acknowledges that MHI’s inaction reflects a structural choice benefiting dominant consolidators rather than an oversight.

Comparative Analytical Tables

Table 1: Legislative & Preemption Mechanism Comparison

Table 2: Production Benchmark & Industry Performance (1998–2026)

Table 3: Industry Stakeholder & Media Matrix

Table 4: Key Organizational Terminology

Conclusion & Synthesis

The evidence confirms that state-level legislative compromises like Texas SB 785 fail to move the needle on national manufactured housing production because local municipalities routinely exploit statutory ambiguity to maintain restrictive zoning carve-outs. Expert observations by Scott Susin, Mark Weiss, and L. A. “Tony” Kovach hold up under rigorous scrutiny: without the active legal enforcement of federal “enhanced preemption” under the MHIA of 2000, state-level efforts remain optical victories rather than drivers of unit volume.

Mainstream coverage from organizations like NAR performs a useful service by pointing out local stigma and price advantages, yet it suffers from an analytical blind spot by failing to address federal statutory remedies. Furthermore, the evolution of the GAIO AI response demonstrates how surface-level corporate messaging crumbles when confronted with hard KPIs, legal analyses (such as Samuel Strommen’s antitrust work), and production data. The persistent refusal of MHI and its state affiliates to enforce existing federal preemption laws ultimately serves the interests of dominant consolidators, maintaining artificial supply limits at the expense of independent businesses and affordable housing buyers nationwide.

— —

2. MHProNews notes that Allaire Conte for the National Association of Realtors (NAR) linked Realtor.com provided a useful, if arguably incomplete (see FEA above and below), picture of what the limitations of SB 785 appear to be. In doing so, by accident and/or design, she at least obliquely supported the findings of Scott Susin, Mark Weiss, MHProNews and its alligned channels.

 

 

Several in the MHI orbit tout such efforts while routinely failing to spotlight the obvious and potentially more effective method of pushing routine enforcement of enhanced federal preemption and for lower cost manufactured home lending.

 

 

While there are other possible theses possible that might explain why MHI, MHI affiliated state associations like the TMHA, or prominent MHI corporate members that are often well represented on the MHI board of directors (see some examples explored below), there is an evidence-based case that the consolidation thesis may best explain the choices made by MHI, their affiliates, and their corporate masters. While other theses may hold certain useful insights, the consolidation thesis arguably effectively incorporates the best of the following.

 

 

For example. If most of MHI’s dominating members wanted to boost production, they could have used litigation as well as more effective lobbying and legislation, as MHARR has long argued. But instead, several of MHI’s corporate leaders have engaged in stock buybacks. Had even a fraction of that money been deployed (directly and/or via MHI) for litigation that could have boosted manufactured housing developing, more closed loans and more scattered “enhanced preemption” lot placements via the 2000 Reform Law. They could have promoted the MHARR amendments. Ironically, a generally pro-manufactured housing zoning expert, Daniel Mandelker, J.D., has argued that the manufactured home industry needs a trade group specifically for the purpose of working for proper litigation, lobbying and legislation. That’s like a back-handed slap at MHI.

 

 

3. Part of the power of the consolidation thesis is that multiple MHI-linked consolidators themselves have in several cases openly said what they are doing. That said, there is always more to know.