‘RV Horizons and Impact Communities Agree to Consent Judgment’ Frank Rolfe, Dave Reynolds, and MHI Leaders Asked to React; MHPHOA Residents Alert, and Memorial Day 2023 Manufactured Home Industry Reflections


On Thursday May 25, 2023 Frank Rolfe, Dave Reynolds, specific Manufactured Housing Institute (MHI) leaders and MHI linked attorneys were asked to comment on “DATCP and Attorney General Kaul Announce $75,000 Judgement Against Manufactured Home Community Operators for Unfair and Illegal Rental Practices.” Specifically, MHProNews asked this via email: “An industry contact provided us a document about this: “DATCP and Attorney General Kaul Announce $75,000 Judgement Against Manufactured Home Community Operators for Unfair and Illegal Rental Practices” Frank and Dave, this is your opportunity to provide emailed remarks or reactions to that release. MHI leaders and attorneys, this would appear to be an issue with respect to the MHI/NCC Code of Ethical conduct. Do you have any comments or reactions to that issue? You know the drill. Please email your remarks. We plan to do a report perhaps as early as Saturday. Thank you.” It is now late Monday morning, 5.29.2023 and no apparent replies have been received. An attempt to search Frank Rolfe and Dave Reynolds connected Mobile Home University website resulted in no apparent hits. The entire document from Wisconsin Attorney General Josh Kaul and Department of Agriculture, Trade and Consumer Protection (DATCP) Secretary Randy Romanski announcement is linked here and is also found herein below along with additional information about the problematic issue. The manufactured home community resident organization MHPHOA had a post on the topic. MHProNews had a previous report and analysis on the issue. There are no apparent direct references to it by others in the manufactured home industry, per various searches linked herein and shown below.

  • Part I of this installment of MHProNews includes a Bing AI chat and search result. Other search engine results are provided further below too.
  • Part II provides the entire remarks issued by WI Attorney General Wisconsin Attorney General Josh Kaul and Department of Agriculture, Trade and Consumer Protection Secretary Randy Romanski.
  • Part III – MHPHOA on this issue and names Frank Rolfe and Dave Reynolds.
  • Part IV provides a reflection on Memorial Day, along with additional information, analysis and commentary on this issue – attention requested by a manufactured housing industry source with the one-word subject line of “Impact” that also provided AG Kaul’s and DATCP Secretary Romanski’s remarks found in Part II.

With that planned outline for the topics covered in this issue, that preface prepares readers for the following facts, evidence, views, and reflections.

Part I Bing AI chat and other search results on AG Kaul RV Horizons and Impact Communities Controversy 

On 5.28.2023 Bing search and Artificial Intelligence (AI) chat function were asked about the following.

Search Inquiry: Wisconsin Attorney General Josh Kaul Consent Judgment RV Horizons Impact Communities Frank Rolfe Dave Reynolds

BingsAIchatAnswerImage-MHProNewsI found some information about the topic you mentioned. It seems that Wisconsin Attorney General Josh Kaul and Department of Agriculture, Trade and Consumer Protection Secretary Randy Romanski announced a $75,000 settlement agreement with Impact MHC Property Management, LLC (Impact), a Colorado-based operator of manufactured home communities (MHCs) in Wisconsin, and RV Horizons, Inc. (RV Horizons), for $75,000 and a series of compliance requirements123The Consent Judgment includes a judgment for civil forfeiture and assessments of $75,000, and payment of the State’s costs of $10,0002.

Is there anything else I can help you with?

Learn more:

  1. manufacturedhomepronews.com 2. datcp.wi.gov 3. einnews.com 4. datcp.wi.gov 5. wislawjournal.com


Part II – Media Release document provided from a manufactured housing industry contact about AG Kaul’s and DATCP Secretary Romanski’s regarding RV Horizons Impact Community Consent Judgment 


DATCP and Attorney General Kaul Announce $75,000 Judgement Against Manufactured Home Community Operators for Unfair and Illegal Rental Practices


Contact: Sam Otterson, Communications Director, (608) 334-0220 sam.otterson@wisconsin.gov  

MADISON, Wis. – Wisconsin Attorney General Josh Kaul and Department of Agriculture, Trade and Consumer Protection Secretary Randy Romanski today announced a $75,000 settlement agreement with Impact MHC Property Management, LLC (Impact), a Colorado-based operator of manufactured home communities (MHCs) in Wisconsin, and RV Horizons, Inc. (RV Horizons), for $75,000 and a series of compliance requirements.

“Wisconsin law provides protections for tenants against certain unfair expenses and practices,” said Attorney General Josh Kaul. “Ensuring that those laws are followed helps protect Wisconsinites’ pocketbooks.”

Since 2018, the Wisconsin Department of Agriculture, Trade and Consumer Protection (DATCP) has received over 50 complaints from tenants at communities operated by RV Horizons or Impact. Most of these tenants own their own home and rent the lot from Impact (or formerly from RV Horizons); some rent both the home and the lot. DATCP’s investigation determined RV Horizons and Impact violated laws that protect tenants in manufactured home communities from unfair rental practices, and DATCP referred these findings to the Wisconsin Department of Justice (DOJ).

“Housing is a basic necessity. DATCP works to enforce the state laws governing landlord-tenant relations and manufactured home communities to protect renters from unfair business practices,” said Secretary Romanski. “Today’s announcement holds two entities accountable for taking advantage of their tenants.”

In its complaint, the State alleges that RV Horizons and Impact engaged in unfair and illegal practices when renting lots to manufactured homeowners. These alleged practices include:

  • Using illegal “exit fee” provisions in rental agreements designed to prevent homeowners from moving their homes to other communities;
  • Overcharging for municipal fees;
  • Failing to clearly disclose how water and sewer charges are billed;
  • Failing to provide 28 days’ written notice of new proposed lease terms;
  • Failing to provide some tenants with new leases upon expiration of an old lease and;  Engaging in an act of constructive eviction by means not permitted by law.

RV Horizons and Impact have agreed to a Consent Judgment that includes a permanent injunction prohibiting them from charging tenants a fee in return for allowing the movement of a manufactured home into or out from a community. The injunction stops enforcement of provisions in the companies’ Wisconsin contracts that effectively imposed such fees. The judgment also includes a two-year compliance monitoring program. RV Horizons and Impact will refund $3,514.14 in overcharges of municipal fees to tenants identified during the State’s investigation; conduct an audit of all tenant accounts going back to January 1, 2018, and credit the accounts of all current tenants with the amount of any overpayment; send a payment to any affected former tenants; and file a report with DATCP. The Consent Judgment includes a judgment for civil forfeiture and assessments of $75,000, and payment of the State’s costs of $10,000.

RV Horizons and Impact deny liability for the State’s allegations.

This settlement was approved by the Joint Committee on Finance on March 7, 2023. ##

MHProNews Editorial Note: the download for the WI state government issued document which provided the information above is linked here. Once more, when invited to respond or react to the above, Frank Rolfe, Dave Reynolds, and MHI leaders and connected attorneys provided no response.s?


Part III – MHPHOA, Google, Bing, Bing AI Chat, Search Results and Email to Frank Rolfe, Dave Reynolds, MHI Leaders and MHI Linked Attorneys

The MHPHOA is a mobile home and manufactured housing resident advocacy website based in California. They are apparently one of only two manufactured housing industry linked sources that carried the gist of the Wisconsin AG Kaul and DATCP Secretary Romanski media release shown above.  See that linked here and here. Per their website: “WEBSITE FOR RESIDENTS: The MHPHOA is NOT affiliated with any mobile home park owners and/or mobile home park management entities. We are both outspoken and anonymous mobile home residents, past and present, just like you, experiencing similar injustices, who want to help.” That brief speaks volumes to those who have the eyes to see and who have a solid grasp of the facts about the manufacutred housing industry and its various advocacy groups, authentic and faux alike. MHPHOA could arguably be a kind of template for manufactured housing independents who ‘fear’ the “predatory” companies and organizations in MHVille and their attorneys.  Because not everyone has the chutzpah of the late Robert “Bob” Van Cleef had as an analogy. MHPHOA reveals that one need not be individual-revealing to spotlight problems in manufactured housing. See Van Cleef in the flashback item below, which is still relevant and insightful over 3.5 years later.




The screen capture linked here from the MHPHOA website reveals much of the same points made by MHProNews in our prior report (linked below) and the DATCP and Attorney General Kaul press release, shown above.



The screen capture of the MHPHOA post is here. The evidence that they are but one of two connected to manufactured housing (the other one is linked above and was on MHProNews) is demonstrated by related search results which are linked here.

Not only did RV Horizons and Impact Communities connected partners Frank Rolfe and Dave Reynolds apparently fail to reply approaching 4 full days after the outreach by MHProNews, which was shown in the first paragraph, above. But an online search that ought to have revealed if there was a post by “Frank and Dave”  on their MobileHomeUniversity.com (MHU) website, this search result linked here ought to have revealed it. There is apparently nothing publicly published from them on this topic.

Note that Frank and Dave claim via their so-called MobileHomeUniversity.com (MHU) website the following.

“Our information is based on 100% truth, with no sugar coating, and both the good and bad aspects of the business are openly discussed. All of our content comes from the real life experiences of Frank Rolfe and Dave Reynolds, who are the 5th largest owners of mobile home parks in the U.S., with over 280 parks across nearly 30 states.”

Certainly, in this test case, several weeks (about 1½ months) after the WI state agency’s press release, that quoted remark by “Frank and Dave” on MHU appears to be proven untrue.  It is worth recalling that when prior MHI chairman Nathan Smith’s SSK Communities, since rebranded as Flagship Communities, was underway, Rolfe publicly ripped Smith for the harm that the litigation was causing to the manufactured home community sector. More on that further below.


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.

To apply the above point by Rolfe to themselves, now that Rolfe and Reynolds have been hit by this and other legal actions involving resident complaints, are they the hypocrites?

Part IV – Memorial Day 2023 Reflections and Additional Information with More MHProNews Analysis and Commentary 

1). “Memorial Day (originally known as Decoration Day) is a federal holiday in the United States for honoring and mourning the U.S. military personnel who died while serving in the United States Armed Forces. It is observed on the last Monday of May.” So, says left-leaning Wikipedia. For years, this publication would pause to reflect that Memorial Day was more than just a day for brats, burgers, grilling, and getaways. MHProNews has probed by the solemn and the celebratory aspects of Memorial Day for years. Several of those reflections are timeless. That means they are as relevant today as they were when initially published.


“Home is Where Our Hearts Are” – President Trump Address to American Housing Professionals

Legacy – Manufactured Home Industry Pro Joseph “Joe” Ellis Obituary – Ike and Jack – Memorial Day Facts, Fiction, and Reflections

Memorial Day’s Grim 100,000 Dead Americans Milestone, Decades of Abuse, Memorial Day Like No Other

Memorial Day Reflections, Donald Trump Jr.’s Surprising Remarks to AMAC, Getting to Root Causes and Common-Sense Solutions to Festering American Problems

Memorial Day – 60 Second Video, Honoring the Fallen Who Preserved Freedom

2. On the one hand, U.S. military personnel over the years that have obtained American freedom and have kept the opportunity for that freedom alive.

People like you, your neighbors, colleagues, manufactured home professionals including the likes of Frank Rolfe, Dave Reynolds – or all others living in America are enjoying the benefits of the freedom made possible by the sacrifices of service men and women – along with their loved ones – through the centuries of American history.

3. That said, the time that some have today to reflect may be an apt opportunity to consider how far afield some of MHI’s prominent members are from what their president and CEO Chris Stinebert said, quoted below.


Paradoxically, what the Castle and Moat methodology are doing is undermining that value. See quote from Buffett, below.

4. An MHI member provided the remarks quoted below. Note that there are some who have consolidated manufactured home communities without doing so in a predatory fashion.



5. The point isn’t that consolidation is per se evil. Rather, it is how, why, with what outcomes, etc. that consolidation is done.  Rolfe and Reynolds arguably got off lightly in this encounter.  More on that linked here in our prior report.

Consider these remarks by Reynolds and Rolfe.


See reports with critical analysis and commentary on Frank and Dave linked below and in other articles linked from this one. https://www.manufacturedhomepronews.com/buffett-berkshire-bust-stunning-charges-frank-rolfe-dave-reynolds-impact-communities-lawsuit-against-residents-mhaction-connection-evidence/


See the report https://www.manufacturedhomepronews.com/mhu-frank-rolfe-dave-reynolds-rip-biden-regime-tipping-point-no-good-news-disastrous-policies-market-risk-vs-mobile-home-parks/ and others linked from this critical report, analysis and expert commentary.

6. Rolfe has argued against building new communities, even though Sun Communities corporate leader Gary Shiffman has said during an earnings call that new communities could be developed at a greater profit than numbers of properties due to “compressed” “cap” rates (see second article linked below for Shiffman’s specific statement).





7. While some in MHVille have questioned the as needed antitrust theme presented on MHProNews/MHLivingNews analysis in the context of various reports, as time has advanced since MHProNews/MHLivingNews has spent time focusing on that oligopoly style of monopolization concern, the evidence as to its relevance and importance has arguably only mounted.


8. Rolfe and Reynolds are partners in community operations that are MHI members.  “Frank and Dave” are also state association members too. MHI has an antitrust statement that is often referred before a meeting session. But the evidence that MHI’s antitrust remarks are akin to the window dressing of their code of ethical conduct has both mounted.

9. While Kevin Clayton, Warren Buffett, and Sam Zell are among those who have danced around – but perhaps implied – the monopolistic practices concerns noted above and herein, Rolfe has been blunt. The quote above about “having a monopoly” and then encouraging others “never” to build a new community is an apparent market-manipulating pitch. That begs the question. Why hasn’t MHI moved against RV Horizons, Impact Communities, or other aspects of their operation? Why instead have MHI given Rolfe a platform at their National Communities Council (NCC) Chicago event? Michael Lebowitz published an analysis that essentially makes the point that Buffett palters. That same pattern of posturing and paltering is apparently true for others in manufactured housing, which could be seen as including MHI itself, Rolfe, Reynolds, Clayton Homes, 21st Mortgage, and several others who have been carefully examined in various reports on our pro-ethical industry growth and pro-consumer platforms.

See CFA Lebowitz’s analysis at the link here: https://realinvestmentadvice.com/a-walking-contradiction-warren-buffett/ and see how we’ve applied that in our inquiry to Berkshire board member and attorney Ronald Olson at the link found further below. https://www.manufacturedhomepronews.com/flashback-friday-enron-worldcom-and-bernie-madoff-lessons-implications-for-manufactured-housing-regulators-and-investors-plus-manufactured-home-investing-stock-updates/



10. Such questions have been ignored by others among manufactured housing industry trade media and/or have been subjected to smear tactics.  It’s odd, given that some in that MHI-linked circle of trade publishers claim to care about independents and consumers.  If so, then why don’t they spotlight the same evidence-based concerns shown here?  It should not even be a question that manufactured home residents and consumers merit to be treated properly.


As atisfiedcustomeristhebestbusinessstrateegyofallmichaelleboueufbrainyquotedailybuisnessnewsmanufacturedhousingindstrymhpronews


Name Calling, Evidence, Facts, and Manufactured Housing’s Primary ‘Muckraker’ Shed Light on Manufactured Home Industry Underperformance; plus Sunday Weekly Headlines Recap


11. With that said, a review of some of the “muckraking” reports on MHProNews and MHLivingNews relative to the folksy sounding MHI members “Frank and Dave” are provided below.















12. If that isn’t enough to cause MHI-NCC to invoke their code of ethical conduct against Rolfe and Reynolds, what is? Recall too that Rolfe and Reynolds were mentioned by Senator Elizabeth Warren in her letters to deep pocketed investors in manufactured home communities. That document is part of the report linked below.



‘Frustration and Hope’ – Law Prof Fran Quigley Slams Frank Rolfe and ‘Wall Street Holding a Gun to Mobile Home Residents’ Heads’ – Statements, Apt Manufactured Home Facts, and Expert Analysis

‘Trapped’ – NBC Spotlights Fannie Mae-Freddie Mac-Fed Roles in ‘Making Mobile Homes Less Affordable’ Fueling ‘Acquisition Spree’ as ‘New MHC Owners Hike Resident Costs;’ plus MHVille Markets Update

13.  Perhaps as or more important than the question of MHI holding Rolfe, Reynolds and their operation(s) up to the so-called standards of their code of ethical conduct, is the issue of manufactured housing operators that have not yet been robustly and routinely subjected to antitrust and RICO actions. While there have reportedly been referrals and discussion, where is the evidence of state or federal follow through?



14. ROC USA’s Paul Bradley has a generally good reputation in the industry. He has said, in his own words, that there are firms that have a problematic reputation. But there are also companies that have a good reputation.  The challenge caused by Rolfe and Reynolds is that their behavior tends to cast a pall over ethical businesses.





There is evidence that a conspiracy to consolidate the manufactured housing industry is hiding in plain sight. The kind of monopolization method could be described as oligopoly.


Summary and Conclusion

Rolfe and Reynolds have been hit by a fine that is relatively modest for millionaires that claim they have over $500 million in market value for their properties.  But that fine might be viewed as a starting point. Where is the follow up by public officials and/or by plaintiffs’ attorneys?  There are plenty of cases in red and blue states of community operators that have been fined and warned. It is time for the kind of robust probe and/or antitrust suits that has been launched against Google or Facebook. There ought to be more than enough evidence found in this and the linked reports to get such an effort authentically launched for the benefit of honest independents and millions of affordable housing seekers and current manufactured home community residents. ###

Has the Manufactured Housing Industry Become a Target-Rich Environment for Plaintiffs’ Attorneys? Facts, News & Views; plus, Sunday Weekly Manufactured Home Industry (MHVille) Headlines Recap

Strommen Manufactured Housing Institute Quote: MHI Mouth Piece of Big 3 Restraint of Trade Should Not Get NOERR protection. https://www.manufacturedhomelivingnews.com/strommen-felony-conspiracy-case-monopolization-of-affordable-manufactured-housing-and-manufactured-home-communities-rube-goldberg-machine-of-human-suff/
Ironically, Skyline Champion’s own investor pitch-deck provides ample evidence for manufactured housing industry underperformance. That same pitch-deck further provides evidence that Mergers and Acquisitions are a key part of their business model. What is there in such revelations that Birch and Williams miss? Bear in mind, that they are mere stand-ins who voluntarily raised their hands in defense of Berkshire and MHI firms like Skyline Champion. Notice: Several of the illustrations shown in this report can be opened in many browsers to reveal a larger size. To open this picture, click the image once. When the window opens, click it again to reveal the larger size photo. Use your browsers back key to return to the article.

Andrew Justus, J.D., Niskanen Center Housing Policy Analyst, Hill Op-Ed Asks and Answers – ‘What’s Holding Back Manufactured Homes?’ Sunday Weekly MHVille Headlines in Review

50 State YTD 2023 Manufactured Home Production, Shipment Data Compared to NAR, NAHB Insights –Stick Builders Up While MH Falls – NAR Says ‘More Inventory Critical’ – Obstacles and Opportunities in MHVille Snapshot

Name Calling, Evidence, Facts, and Manufactured Housing’s Primary ‘Muckraker’ Shed Light on Manufactured Home Industry Underperformance; plus Sunday Weekly Headlines Recap



Trade media can and should be a ‘cheer leader’ when it is appropriate to do so. But authentic trade media also holds the powers that be to account. Who says? The American Press Institute.
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Our son has grown quite a bit since this 12.2019 photo. All on Capitol Hill were welcoming and interested in our manufactured housing industry related concerns. 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, bottled water, and other goodies.

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.


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



Related References:

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

2023 ‘Excellence in Manufactured Housing Awards’ – Claims, Facts, Op-Ed Practically Writes Satirical Saturday Column on Manufactured Housing Institute’s Sly ‘Awards’ – plus, MHVille Markets Update

“Played”-Publicly Traded Manufactured Housing Institute (MHI) Members, MHI News Update Reveals True State of Manufactured Housing Industry in May 2023-Facts, Analysis, and MHVille Markets Update

Aging Warren Buffett Led Berkshire Hathaway Invests Billions in Asian Firm, Soon Sells Most in ‘Red Flag’ Issue for Dozens of Manufactured Housing Producers; plus Sunday Weekly Headlines Recap

True State of the Manufactured Housing Industry in March 2023 Based on Facts, Not Clever Agenda-Driven ‘Fiction$’ – plus Sunday Weekly MHVille Headlines Recap

MHI ‘Special Bulletin’ DOE MH Energy Regs Lawsuit ‘Effort to Ensure Consistent Industry Message,’ Will Manufactured Housing Institute Launch More Suits? Plus Sunday Weekly MHVille Headlines Recap

Danny Ghorbani – Manufactured Housing’s ‘Elephant in the Room,’ per Prior Manufactured Housing Institute Chair, Exclusive Q&A on Key MHIndustry Issues, plus Sunday Weekly MHVille Headlines Recap




‘Affordable Homes for Low Income Must Produce in Factory,’ ‘Years to Unravel Sabotage,’ Grad Students Interest in Manufactured Housing, Factory-Home Solutions; plus Sunday Weekly Headlines Recap


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