Official Modular Builders, Manufactured Housing and HUD Stances on Coronavirus Crisis, Controversies – and Silver Lining?

Still from HUD video further below, text graphics by MHProNews.

There is no denying that the construction industry has been as upended in several respects as other sectors of the American or global economies. The COVID19 pandemic has caused some states to close down construction by factory builders, while other states have permitted it. Furthermore, mortgage servicing, rental and an array of other impacts on housing have occurred and/or are still looming. Federal officials are striving to respond to these issues, which is reflected in the “unanimous” 96 to 0 vote by the U.S. Senate last night to pass a record estimated $2.2 trillion dollar relief package that aims to support the working and middle class, smaller businesses and larger businesses too. The House is scheduled to take up that bill on Friday, which is widely thought will pass, and President Donald J. Trump has indicated he will promptly sign into law.


From 7 million open jobs begging to be filled, to some 3.28 million jobless claims have just been reported. What a change just a few weeks has made. That’s reportedly more than 4 times the level going into the Great Recession of 2008.

With that brief backdrop, each aspect of the headline will be covered in a systematic fashion using the following format.

  1. The first source to be considered will be the statement and video from HUD’s Brian Montgomery, J.D., Assistant Secretary for Housing and Federal Housing Commissioner addressing certain points with respect to FHA and borrowers.
  2. Second will be followed by communications from a manufactured housing trade group to HUD Secretary Carson.
  3. Third will be a letter from a modular housing and construction trade group.
  4. That will be laced with some observations to guide new readers and provide others with some context, and will followed by an MHProNews analysis and commentary.

With that format, let’s begin.


Part 1.

Dear Stakeholders,

Please take a moment to view my message below, which contains information about the steps we are taking to ensure FHA’s many borrowers, lenders, property owners, agents, and business partners understand the status of our operations and our plans as health and economic events unfold and evolve.


To read a copy of the video transcript, please click the attachment.


Brian Montgomery

Assistant Secretary for Housing and Federal Housing Commissioner



At the time this report is being drafted, the video above has had 796 views on Mar 17, 2020. Perhaps the low totals is due in part to people reading the transcript vs. watching the actual video. That transcript is found at this link here.

New readers as well as long-standing ones are reminded of the principle of separating the wheat from the chaff employed by MHProNews. That noted, MHProNews has raised concerns about Mr. Montgomery, which are found at the link below.


Trump Administration Asked to Withdraw Brian D Montgomery Nomination Over Conflicts of Interest



Part 2.

Manufactured Housing Responds to Evolving Events

On paper, a larger organization can have certain advantages in terms of manpower, resources, insider information and money. But smaller organizations can often prove to be nimble and adaptive when necessary.

In response to the evolving circumstances with respect to the coronavirus/COVID19 outbreak, the Washington, D.C. based Manufactured Housing Association for Regulatory Reform (MHARR) has planted their own flag on the issue of protecting the industry’s independent producers of HUD Code manufactured homes which that nonprofit represents.

Perhaps due to their understanding of HUD Secretary Carson’s routinely stated support for manufactured housing, MHARR took the following steps. The cover message to their members and other interested parties is below.


MARCH 24, 2020




FROM:           MHARR


Attached, for your information, is a copy of a self-explanatory MHARR letter to HUD Secretary Ben Carson. This matter, and other aspects of the federal COVID-19 response, will be addressed in further detail as part of the MHARR Board of Directors meeting next week.

In a related matter, a communication from HUD Assistant Secretary for Housing/FHA Commissioner Brian Montgomery, is set forth below as well for your (and your post-production sector colleagues’) review and information.

We look forward to your participation in the re-scheduled MHARR Board meeting.  Please do not hesitate to contact us if you have any questions.

cc:  Other Interested HUD Code Industry Manufacturers, Retailers, Communities and Finance Companies


That attachment reads as follows.




March 24, 2020




Hon. Ben Carson


U.S. Department of Housing and Urban Development

Suite 10000

451 Seventh Street, S.W.

Washington, D.C. 20410


Re: Federal COVID-19 Response — Manufactured Housing


Dear Secretary Carson:

I am writing on behalf of the members of the Manufactured Housing Association for Regulatory Reform (MHARR). MHARR members, as you know, are mostly smaller, independent producers of federally-regulated manufactured housing located throughout the United States.

As smaller businesses which, in many cases, are family-owned, these independent producers of affordable HUD Code manufactured housing face unique and daunting challenges in connection with the COVID-19 pandemic and the unavoidable economic dislocation occasioned by the strong measures needed to combat both its spread and duration within the United States.

Notwithstanding these pressures, the independent manufactured housing producers that we represent in the nation’s capital stand ready to do their part, wherever and whenever needed — by any level of government or as part of a private sector initiative — to provide the type of inherently affordable, rapidly-deployable housing, shelter and related facilities that may be necessary to help the American people meet the challenges they face today and to recover, as rapidly as possible, once the pandemic begins to recede.

In order, however, to maintain the industry’s essential infrastructure (including both facilities and people) to the greatest possible degree, to meet this need and the future housing needs of the nation, we urge you to take all steps necessary and proper to: (1) ensure that the production, sale, transportation and installation of federally-regulated manufactured homes are treated as “essential” economic activity for all purposes at all levels of government; (2) ensure that federally-regulated manufactured housing is included in any and all relevant government response programs or initiatives; and (3) ensure that manufactured home producers are eligible for all available forms of economic relief provided to other “essential” industries and small businesses in particular.

The manufactured housing industry has a long history of “stepping-up” to meet the nation’s housing needs in times of crisis and emergency. That commitment remains as strong today as it ever has. Our members look forward to the opportunity to serve America and Americans as our nation meets and overcomes the current challenge.


Mark Weiss

President and CEO


cc: Hon. Mike Pence



The original letter from Mark Weiss, J.D., to HUD Secretary Carson is found at this link here.


For industry newcomers or those dipping their toes into the professional side of the world of HUD Code manufactured homes, there are two primary national trade groups. MHARR states that they represent the interests of the independent producers of HUD Code manufactured home, which make up their members.

While they take stances that may be supportive of manufactured home consumers, prospective home owners, retailers, community operators, developers, affordable housing advocates, investors, taxpayers or others – their stated focus remains regulations relating to the interests of HUD Code manufactured home builders.


By contrast, the Arlington, VA based Manufactured Housing Institute (MHI) states “We are the only national trade association representing all sectors of the manufactured and modular housing industries.” That is phrased in a variety of ways on their own website. For instance, “The Manufactured Housing Institute (MHI) is the only national trade organization representing all segments of the factory-built housing industry. MHI members include home builders, retailers, community operators, lenders, suppliers and affiliated state organizations.” Those quotes are both from the MHI website on this date and time.

MHI’s response to these developments will be examined in a separate report. But relevant prior background on MHI and COVID19 can be found at the report linked below.


Marty Lavin, Modular Builders, and Manufactured Housing Institute – on COVID19 – Coronavirus Disaster Impacts and Plans


That noted, the Modular Building Institute (MBI) which is focused on commercial modular construction applications, and the Modular Home Builders Association (MHBA) takes exception to positions held by MHI. So does MHARR.

The MBI recently sent this comments letter to HUD’s Office of Manufactured Housing Programs administrator Teresa Payne, J.D.





Teresa B. Payne,
Administrator Office of Manufactured Housing Programs,
Office of Housing U.S. Department of Housing and Urban Development
451 7th Street SW
Washington DC 20410


RE: Manufactured Home Construction and Safety Standards Proposed Rule (FR 2020-01473)


Dear Administrator Payne,

On behalf of the Board of Directors and members of the Modular Building Institute, I am writing to you today to request an extension to the public comment period associated with the Manufactured Home Construction and Safety Standards Proposed Rule (FR 2020-01473)(Proposed Rule). Due to the current Presidentially-declared National Emergency in response to the outbreak of COVID-19, the Department of Housing and Urban Development should extend the comment period for this Proposed Rule for an additional 60-days to give stakeholders ample opportunity to coordinate their comments as state governments mandate the implementation of social distancing guidelines provided by the Center for Disease Control and Prevention (CDC).

As the international trade association for the modular building industry, we have a number of concerns that the Proposed Rule is an unwarranted encroachment into our industry’s sector. However, due to the current public health crisis, our members are currently working with their state and local governments to offer additional available modular and relocatable building structures to support hospitals and public officials with patient surge capacity. As such, our capacity to offer substantive comments is limited.

Thank you for your consideration of this request. Finally, we reserve our right to submit additional comments to the docket.




The original MBI letter is found as a download at this link here.



Part 4.

MHProNews Analysis and Commentary

The proverbial dark cloud has potential silver linings. There will be winners and losers from this current crisis, that much is certain. In as much as tens of thousands have died and untold millions around the world have been thrown out of work unexpectedly, those ‘losers’ are in some ways self-evident. But by contrast there are also, as last night’s market report reflected, those with deep pockets that are licking their chops to cash in on the sudden plunge in valuations of stocks and other items.


‘Fundamentally Good Businesses Will Have Terrible Year,’ Private Equity Moving for Bargains, plus Manufactured Housing Investing, Stock Updates


Even before the gravity of the current COVID19 pandemic – which the pro-Chinese, but arguably anti-communist Epoch Times refers to as the CCP Virus (Chinese Communist Party Virus), and others have referred to as the Wuhan or China Virus – became apparent in the U.S. and our industry, there were actions and inactions by various parties. MHI for weeks stayed focused on updating their members about their upcoming event, which was finally cancelled. MHProNews stayed focused on a broader array of issues that provided some context for readers to consider as they navigated difficult and in some ways uncharted waters.

MHI has after some delays finally launched what will appear at a glance to be an impressive array of resources. But as the report linked here and above indicates, much of that is arguably not much more than cutting, pasting and tweaking the groundwork already performed by others. In doing what they do, they promptly purportedly pat themselves on the back in their own messages and then seemingly ask their members to gaze in wonder as to how amazing they are.

At some point, MHProNews will take a deeper dive into the most recent items produced by MHI. The principle of separating the wheat from the chaff should be applied to it, as with all other sources.

But what the two messages above, from MBI and MHARR, do is pose a stark contrast for MHI members, affiliates and others to consider. If MHI were truly representing “all segments” as well as they claim, would there be any need for MHARR, MBI or the MHBA? Similarly, the reason that the National Association of Manufactured Housing Community Owners (NAHMHCO) launched is because they specifically stated that MHI had failed to represent their interests.


All such quotes should not be construed as a blanket endorsement of all that a person or organization has said or done. Rather, with quotes or other references, we apply the principle of separating the wheat from the chaff. There are good reasons to source insights and relevant comments across an array of topics and viewpoints.


One can then ponder how well NAMHCO has done since they launched, that is a worthwhile discussion. But these are three sources independent of MHProNews and MHLivingNews that publicly and repeatedly directly or de facto questioned MHI’s effectiveness at doing their stated mission.

Rephrased, MHI is clearly not doing what they claim to do, are they?

The evidence that they have failed is found in black and white data. During an affordable housing crisis, manufactured housing actually took a dip in 2019, as MHI had to admit with the arguably twisted spin shown below.


MHI’s own recent admission that shipments declined logically debunks their claim of ‘momentum.’ MHI has been repeatedly accused of paltering, which will be examined below and in linked articles.


When one steps back and looks at the trends, it becomes ever more clear that the industry has underperformed since at least 2003. What occurred that year? The acquisition of chunks of the manufactured housing industry by the Berkshire Hathaway conglomerate. Warren Buffett led Berkshire clearly has the resources to do all that they might desire in manufactured housing, as Kevin Clayton stressed in the video interview with complete transcript that is found in the report linked below.


Warren Buffett’s “Moat” per Kevin Clayton, CEO Clayton Homes Interview Transcript, Video – Affordable Housing and Manufactured Homes


That begs the question. If “Warren” is willing to support Clayton Homes, their lending, retailers, suppliers and other entities financially as needed, then why is manufactured housing underperforming?

To grasp that answer, one need not do much more than listen to what Kevin Clayton said himself.


See the full context in the ‘read hot’ report linked here.


But to emphasize the point, consider what other financial writers and analysts have said in recent years about Buffett and Berkshire. One politely says that Buffett sometimes says one thing but does another. Call that a head-fake, paltering, a lie, whatever – that writer called it contradictions.  Note that he also emphasized the word, “Monopoly.” and specifically notes the “moat” that Kevin Clayton and Buffett have spoken about.



Another financial writer stated that Buffett’s method is monopolistic and designed to be anti-competitive. Using different words, it makes a point akin to Kevin Clayton’s quote above.  Robin Harding stresses “the moat,” just as Michael Lebowitz did.  Think of the moat as tactics designed to hobble competitors. Or as Kevin Clayton said, “some of our competitors do a good job, but ours plans are to make that difficult for them.”



Clayton arguably didn’t go into a similar level of detail in the interview linked here on their use of nonprofits as he did on the moat strategy. But the use of nonprofits to advance their ‘education’ agenda is noted. When Buffett’s mantra about the moat is noted as metaphorically using sharks and other deadly predators, these should be sufficient for industry professionals to realize that both accidental and/or triggered or caused events could be part of the Buffett-Berkshire-Clayton scheme. MHI, which Berkshire dominates in several ways along with a few ‘big boy’ allies, makes the matter clearer still.




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Simplified, what MHI, Clayton, Buffett or an ally such as Bill Gates says ought be to seen through a skeptical lens. Industry professionals, investors, attorneys, public officials and others investigating Clayton or Berkshire should bear this pattern in mind.  Their is ample evidence from credible sources both inside the manufactured and modular housing industry, plus those on the outside looking in to support the contentions and concerns that MHProNews and others have been raising for some years.


See report linked here.




That article linked above has been one of the consistently most read articles on MHProNews since it was originally published. While some are no doubt industry professionals, others are arguably those who have an axe to grind with Clayton and/or their lending.

Boiled down, this COVID19 crisis can be seen as an opportunity for more industry professionals, investors and others to dig into the details that shed light on what has gone wrong that keeps manufactured housing underperforming, some 15 years after Berkshire Hathaway bought into it.






Every resume, every corporate snapshot is a kind of historic outline. History is something that Buffett believes in using, but he bluntly said that he thinks most ignore history. That may be sadly true, but that is a reason to pay more attention to the relation of past events to present ones.






To learn more about the issues that the evidence indicates has purportedly shaped years of underperformance by manufactured housing, see the related reports below the bylines and notices.

Danny Glover quote from the fascinating video documentary, Shadows of Liberty, you can stream it.

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Stay tuned for more from the industry’s largest, most read and leading trade publication on exclusive news, analysis and other issues – MHProNews. That’s in for this installment of “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, further below. Text/image boxes often are hot-linked to other reports that can be access by clicking on them.)

All on Capitol Hill were welcoming and interested with the discussion of manufactured housing related issues on our 12.3.2019 meetings. But Congressman Al Green’s office was tremendous in their hospitality. Our son’s hand is on a package that included the Constitution of the United States and other goodies.  MHProNews has worked with people and politicos across the left-right divide.

By L.A. “Tony” Kovach – for

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

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Related References:

The text/image boxes below are linked to other reports, which can be accessed by clicking on them.

COVID19 Cases Reported at Clayton Homes Plant, Keith Holdbrooks Namedrop – Claims, Backdrop and Analysis

Facts from ER Doc on COVID19; plus, Nobility Homes Sales Data; Other Manufactured Housing Industry Producers – Obstacles and Opportunities

Are Manufactured Housing Supply Chains in China Threatened by Coronavirus?

Events Canceled Due to Coronavirus Fears, Manufactured Housing Institute Spring Meeting Update, Plus Sunday Week in Review 3.1 to 3.8.2020

Markets Plunge Again, Industry Equities Tank, $1Trillion Move by Fed, Can’t Have it Both Ways; plus Manufactured Home Investing Stock, Updates

The featured image includes several metaphorical items. It can be seductive – but dangerous – to believe certain things. A mask, among other meanings, is used to project a false face, often used by actors. The eye conveys vision or understanding, which that woman and the mask partially obscures. The wall can stand for the harsh reality that sets in when illusion and the hard facts meet.

China Coverup Timeline – Axios, Southampton U – Delays Cost Countless Lives, U.S., World Trillion$; plus Manufactured Home Investing, Stock Updates

2020 Tunica Manufactured Home Show Cancelled, Manufactured Housing Institute Event Apprise, plus Manufactured Home Investing, Stock Updates

Market Analyst Craig Kucera on UMH Properties, “Never Let a Good Crisis Go To Waste” – Industry, Investment, National Insights

“Be Greedy When Others are Fearful” – Bill Gates, Warren Buffett and Follow the Money, plus Manufactured Home Investing, Stock Updates





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