Shelterforce–‘Making Homeownership Affordable-Bringing Fannie and Freddie Back to Mission’ and ‘Illusion of Competition.’ AmeRegCorp Update. Plus Sunday Weekly MHVille Headlines in Review
“The federal government didn’t want to give Fannie Mae monopoly power in that realm, and so they created Freddie Mac, basically, as competition—[or] at least the illusion of competition.” So said George McCarthy, President and CEO of the Lincoln Institute for Land Policy in the linked Shelter Force article: “Making Homeownership Affordable: Bringing Fannie and Freddie Back to Mission, a Shelterforce Webinar” on 4.30.2026 is this subheading. “Fannie Mae and Freddie Mac guarantee most U.S. home loans, which is supposed to make homeownership widely accessible. But is this happening? In this webinar, three field leaders argue that these government-sponsored enterprises need to step up with new products and services to expand access to homeownership.” The article is by Steve Dubb, who is listed as Shelterforce’s strategic initiatives editor and is also the moderator of the webinar video posted below in Part II. Based in part on several interesting remarks in that panel discussion with transcript, MHProNews has contacted Shelterforce’s Dubb and George McCarthy at the Lincoln Institute for comments and to request certain actions. For those who are – or should be – following the developments with the pending Congressional legislation dubbed by the Senate as the 21st Century ROAD to Housing Act, the following discussion makes a potentially useful lead into this Sunday Weekly MHVille Headlines in Review.
1. Related to the Saturday report (see weekly headlines recap further below in Part III), the following update about the Neologism portmanteau AmeRegCorp. Per two Google searches as shown. Prior to MHProNews coining that term, there was no results for that search.
Not long afterwards, it now appears in a Google search result as shown below. Pro-tip: putting a search term in quotation marks tends to force a search engine to look for that specific phrase as typed.
2. Every result above is found on the industry’s leading trade media site, MHProNews. A new term – AmeRegCorp – is born which Gemini defined as follows.
AmeRegCorp (n.):The symbiotic consolidation of American regulatory agencies and dominant corporate entities, resulting in a market structure that favors established players while suppressing independent competition through legislative and financial bottlenecks.
3. Note that among the other headlines in Part III is about a U.S. Treasury event that included Secretary Scott Bessent and AMAC that MHProNews’ L. A. “Tony” Kovach was invited to attend. Kovach is in the photo on the left with Sec. Bessent and others from the AMAC delegation.
We discussed the importance of equipping Americans across all stages of life with the tools to make informed financial decisions and protect themselves from fraud and… pic.twitter.com/yg9k9kDW2X
— Treasury Secretary Scott Bessent (@SecScottBessent) April 29, 2026
4. Per Copilot (see Part III Postscript).
What to keep clear in the article
Their scope vs. yours: Shelterforce/Lincoln are talking about overall homeownership affordability and GSE mission drift. Manufactured housing and DTS are your [MHProNews] extension of that logic, not their explicit focus. Make that distinction explicit so readers don’t think the panel itself was about MH/DTS.
That’s fair enough, but MHProNews must be noted that Shelterforce/Lincoln explicitly mentioned manufactured housing in what followed. Quoting:
They were asked to serve markets [such as] manufactured housing, rural markets, and low- and moderate-income borrowers, as well as even multifamily markets.
Also, per Copilot further below.
That’s the “for the sake of argument” move you’re making: grant their sincerity, then test whether their actions (or inaction) line up with their own diagnosis.
And…
“Congress imposed a Duty to Serve manufactured housing. FHFA’s rule, however, treated key activities—like chattel lending—as discretionary, even while panelists and UMMC members now describe, in detail, how lower‑income and rural borrowers remain underserved. If they are serious about fixing that, the logical next step is to support amendments—such as those advanced by MHARR—that would make ‘duty’ a real mandate in practice, not just a word in a statute. If they decline to do so, that silence itself becomes part of the AmeRegCorp story.”
That centers exactly what you’re after: not FHFA’s fact sheet, but the contradiction between what the law says, what the evidence shows, and what key actors are (or aren’t) willing to publicly support.
Part I. The following remarks were posted on Shelterforce. regarding the video and transcript that follows. Note that the spacing may differ slightly from what was posted but the text remains the same.
Interesting discussion, thanks. For the sake of argument, let’s accept the thrust of this discussion as being sincere and let’s take the history and claims of each participant in this panel discussion at face value. Doesn’t that beg several questions of participants?
Why hasn’t Shelterforce, or for that matter other participants in this panel discussion, publicly support a call for endorsing what the Manufactured Housing Association for Regulatory Reform (MHARR) has consistently and persistently encouraged for months (years, actually). Namely that the Duty to Serve (DTS) manufactured housing (and by extension, the underserved markets) be rigorously mandated by adding it as an amendment to the pending legislation, regardless of what else may emerge from the House and Senate conference committee discussions?
Some form of that same question should be posed to each of the panelists and to the entire Underserved Mortgage Markets Coalition more broadly. There are arguably several fine points each of you have raised. Let’s be clear. Neither Democrats nor Republican Administrations in the 21st century have enforced DTS properly, or this panel discussion wouldn’t have been needed.
Neither major party have enforced the “enhanced preemption” provision of the Manufactured Housing Improvement Act of 2000.
But you have sitting in front of you the mechanism to compel change through mandates that must in practice BE an actual MANDATE. Fannie, Freddie, the GSEs more broadly, need to support the Duty to Serve manufactured housing. Several of your organizations have at various times promoted the need for more manufactured housing to serve the entry level, upsizing, or downsizing homebuyer. Some of you have recognized that local zoning barriers need to overcome in order to make that happen. The proposed MHARR amendments would do precisely that, if they were adopted. So why not publicly call for the adoption of those amendments? https://manufacturedhousingassociationregulatoryreform.org/?s=amendments
Part II. The Shelterforce.com Webinar Video and Transcript
Per the YouTube page for the video below: “This webinar examines how two leading government-sponsored enterprises, Fannie Mae and Freddie Mac, who help sustain the national housing market, support or fail to adequately support homeownership for Americans of modest means. While their missions are to support affordable housing, a March 2026 video by the Lincoln Institute of Land Policy ( • How Fannie and Freddie Can Help Make Housi… ]/) suggests they have strayed from mission and need to step up with new products and services to expand access to homeownership. Shelterforce’s Steve Dubb facilitates a conversation that explores these issues and more with George “Mac” McCarthy, President and CEO of the Lincoln Institute for Land Policy; Sara Morgan, President of Fahe, a large regional community development financial institution loan fund based in Appalachia; and Tony Pickett, CEO of Grounded Solutions Network, a national network of over 300 community land trust and shared equity housing providers.” And: “Recording note: Due to technical difficulties, the live recording of the webinar begins at 11:33. The first 11:33 of the recording, including George McCarthy’s overview of the history of Fannie Mae and Freddie Mac, was re-recorded after the live event.”
George McCarthy, president and CEO of the Lincoln Institute of Land Policy
Sara Morgan, president of Fahe
Tony Pickett, CEO of Grounded Solutions Network
Watch the full video above or read a lightly edited transcript of the conversation below.
Their transcript provided was as follows. Yellow highlighting was added by MHProNews.
Steve Dubb: Hello. I’m Steve Dubb. My pronouns are he and him, and I’m [the] strategic initiatives editor here at Shelterforce, coming to you from Boston on land historically stewarded by the Massachusett Nation. Over the past years, I’ve participated in many joint webinars with Shelterforce, but this is my first time moderating for Shelterforce. I am pleased to have joined the Shelterforce team. We look forward at Shelterforce to hosting many additional webinar conversations this year.
For this webinar, “Making Home Ownership Affordable: Bringing Fannie and Freddie Back to Mission,” Shelterforce is pleased to partner with the Lincoln Institute of Land Policy, which just last month published a 16-minute video on how the government-sponsored enterprises Fannie Mae and Freddie Mac were created to support housing affordability but need to adjust their strategies to meet their mission of promoting affordable homeownership today. This webinar aims to expand on and deepen the discussion of how this can occur.
For our webinar, we are joined by three expert panelists. George McCarthy is [the] president and CEO of the Lincoln Institute of Land Policy. Sara Morgan is [the] president of Fahe, an Appalachian-based community development financial institution. Tony Pickett is [the] CEO of Grounded Solutions Network, a national group that supports community land trusts, deed-restricted housing, and inclusionary housing.
I want to begin with Mac. Can you introduce yourself briefly, talk about the Lincoln Institute for Land Policy, and talk about why Fannie and Freddie exist—and why these institutions are so important in our housing system?
George McCarthy: Sure. Thanks, Steve. Thank[s], everybody, for joining us. It’s a topic near and dear to my heart. Hopefully, it’ll be near and dear to yours by the time we’re through. The Lincoln Institute of Land Policy [is] an 80-year-old think tank working on finding ways to use land policy, land-based financing, any ways that land can be deployed to address larger social, environmental, and economic challenges. Fannie Mae and Freddie Mac, otherwise known as the GSEs, the way I see it … were created to fix structural failures in the housing finance system.
In order to understand that, you have to go back to their origins. Their origins come from the Great Depression. During the Great Depression in 1932, the banks collapsed. One of the reasons the banks collapsed was because they were holding mortgages on properties that were all bought or refinanced during the 1920s. In the 1920s, the typical mortgage was a 50 percent loan-to-value ratio, interest-only note with a five-year duration. What that meant was that people would put half of the money down, buy their home, and then they would pay interest on the note. After five years, the bank would ask them either to pay off the balance or they would refinance them. Typically, they would refinance them.
When money was short and people started to lose [their] jobs, they also lost their ability to pay their mortgages. They certainly didn’t have enough money at the end of a five-year period to buy their home. The banks were running out of liquidity because people were defaulting on mortgages. They didn’t even have enough money to cover their deposits. The banks weren’t willing to refinance; they were offering people the opportunity to either buy their home or lose it in foreclosure. As you already know, millions of people lost their homes in foreclosure during the Great Depression.
The way forward, certainly with FDR, was the New Deal. The New Deal was just a way to keep the country together and to keep it together in a centrist fashion. The primary way [the government] did it was by really extending homeownership to as many people as possible by creating the housing finance system. That was based primarily on a new invention in the 1930s: the 25-year self-amortizing mortgage. This was created by a thing called the Home Owners’ Loan Corporation, which was also a way of helping people to avoid foreclosure on their loans.
Banks were reluctant to be lending out at 25 years at a time, especially after they’d been pushed to the brink of bankruptcy themselves by their housing finance system or by the mortgages they were holding. The federal government decided [it] needed to do something else. [It] created the Federal Housing Administration as a way to assure banks that if they’re willing to lend long—25 years—the federal government would stand behind the borrowers, and in the event that the borrowers couldn’t pay their mortgages, the federal government would jump in and pay their mortgages on their behalf.
This was the first financial guarantee that we’d seen established in the housing finance system anywhere in the world. Banks said, “Sure, we’ll lend long if the [Federal Housing Administration] will guarantee it.” They started lending to people to refinance their old mortgages or buy new homes. They did it so well that they ended up running out of money. All the banks were sitting on all these mortgages, these 25-year mortgages on their balance sheet. They didn’t have any more money to lend, and they needed a solution.
The federal government once again came to the rescue by creating a secondary mortgage market in the form of Fannie Mae Corporation. The way that worked was Fannie Mae would buy the mortgages off the balance sheets of the banks. They would issue their own debt in the form of bonds, and then they would pay off the bonds with the proceeds from the mortgages when people paid their mortgages back. The money that they used to buy the mortgages from the banks went back onto the balance sheets of the banks, so they could lend again and lend to new people to buy mortgages.
This was phenomenally successful. It created a multi-trillion-dollar housing finance system in the United States, and it helped about two-thirds of American families become homeowners by the 1960s. The other thing was that even with their ability to issue debt, issue bonds, and buy mortgages, and then pay off borrowers, the idea was that there still wasn’t enough money available for Fannie Mae and Freddie Mac to continue to fuel this housing finance needs of the country. In 1969, Fannie Mae was given permission to securitize.
Securities were created where Fannie Mae would buy mortgages off the balance sheets of banks, but instead of issuing their own bonds, they would bundle them into mortgage-backed securities and then sell the securities themselves to investors around the world. Basically, what this did was it opened up the housing finance system to global capital markets. The federal government didn’t want to give Fannie Mae monopoly power in that realm, and so they created Freddie Mac, basically, as competition—[or] at least the illusion of competition.
They now had two entities that could do exactly the same thing, which was to buy mortgages off the balance sheets of banks, bundle them into mortgage-backed securities, [and] sell them to global investors. That just really, really ginned up the housing finance system [in the long term]. Anyway, for at least their first 40 years, it seemed like the GSEs’ main goal in the world was to provide liquidity for the housing finance system. That was true, but it was also true that they did other things. They created very efficient executions in the mortgage system. They really found a way to professionalize and build up housing mortgage originators who would then originate the mortgages and sell them to Fannie and Freddie.
They created a system that was the rival of the world, frankly. It wasn’t just liquidity, and it wasn’t just efficiencies, because the federal government also decided that Fannie and Freddie, because of the privileged position they had … had access to the low-cost debt. They were the only two entities allowed to securitize this debt into the global markets—they really owed the taxpayer something else. What they owed the taxpayer was the commitment to solve other structural problems in the housing finance system, primarily reaching people that otherwise wouldn’t be reached by the housing finance system, providing products that otherwise wouldn’t exist until they were invented by Fannie and Freddie, and later, really being able to establish housing finance in new markets through what they call Duty to Serve.
Basically, there were goals and mandates that were layered onto Fannie and Freddie by the federal government called Affordable Housing Goals [and] Duty to Serve Goals. They were asked to serve markets [such as] manufactured housing, rural markets, and low- and moderate-income borrowers, as well as even multifamily markets. All in all, Fannie Mae and Freddie Mac, the GSEs, were created to be problem-solvers. That’s what they did really successfully … basically through the great financial crisis when things went bad and the federal government had to take them over in conservatorship.
Since then, they’ve actually lost their mojo, and they are not problem-solvers in that same way. Hopefully, with our help and the help of others, we’ll persuade Fannie and Freddie to become the problem-solvers that we know … they can be and [that] they have historically been.
Sara, can you introduce yourself briefly and talk a little bit about Fahe and how the operations of Fannie Mae and Freddie Mac support housing affordability today—and where they fall short, from your perspective?
Sara Morgan: As a [Community Development Financial Institution], we reach a part of the market that the traditional market doesn’t meet. We’re working with low-income borrowers, and we’re working in low-income communities. Being able to be credentialed with a Fannie or Freddie seller-servicer status means people can understand us differently than the niche-y CDFI world. That was huge. Unfortunately, in rural America in particular, there’s less [of a] liquidity period, whether that’s at an individual homebuyer’s individual balance sheet or at a community level. Where I think Fannie and Freddie both do a terrific job is if you’ve got good credit and you’ve got liquidity—you have your own personal liquidity—they can make those loans all day long.
Where it’s harder is when you’re in places where folks are lower income, [such as] Appalachia, where we have many communities that are persistently poor, and folks don’t have six months of cash in the bank, and they have multiple risk factors. Fannie and Freddie struggle there a little bit. I think we could help them learn to do more.
Thanks, Sara. Tony, could you introduce yourself briefly and talk about, from your perspective and Ground Solutions’ perspective, where Fannie and Freddie are supporting affordability today and where they are falling short?
Tony Pickett: Sure, Steve. Thanks. Yes, I’m the CEO of the Grounded Solutions Network. We are a national network of around 300 members. Steve, as you alluded to earlier, we support a variety of nonprofits and municipal governments [that] are all focused on expanding affordable homeownership using a very unique approach called shared equity homeownership—providing affordable homeownership but keeping the same home affordable upon resale.
There are resale restrictions that go along with shared equity homes, and those homes are also stewarded, really, by nonprofit programs [that] really have the best interest of the family who’s buying that shared equity home, making sure that they’re successful in maintaining homeownership. We’ve worked with Fannie and Freddie in the underserved mortgage markets work. They consider shared equity one of those markets that Sara mentioned earlier. We’ve really focused with them around figuring out ways to increase the volume of shared equity mortgage lending.
Our members over the years have reported to us [that] one of their biggest challenges is accessing shared equity mortgage lending. Individual lenders … as we said earlier and as was said in the video for this webinar, because they’re not familiar with it, they resist lending [and] making those types of loans. We want to open up that lending channel in partnership with both of the GSEs. Over the years, that has focused on different things, but I’ll just talk about three primary things that [have] resulted from … our partnership with the GSEs.
One is [that] we have standardized shared equity ground leases. One of the methods that is used frequently to create shared equity homeownership is a community land trust. That’s probably the most familiar model to folks. It employs, typically, a ground lease, although it can use a deed covenant as well. The ground lease really needs to be based on our template in order for the GSEs to really offer to purchase the loans that are made using those ground leases. We also have created a model deed covenant to cover those instances when the ground leases aren’t used … that both GSEs recognize today.
Also, shared equity program certification. Really, certifying that programs actually have the basic capacity to operate a shared equity program. Certifying that those nonprofits can actually successfully run the programs. That’s designed to ease the underwriting burden for lenders who want to make those shared equity mortgage loans.
Thirdly, we partnered several years ago with Freddie Mac and modeled what was called, then, a single-family rental portfolio to shared equity transition.
We really looked at [whether acquiring] portfolios of single-family homes … that are offered up by, say, private equity interests, and operate those as rental properties for some period of time [and] allow equity to build up in those homes and use that equity as the subsidy to convert them to affordable homeownership … would open up a larger pipeline of shared equity homeownership opportunities. We’ve been successful in not only modeling that [but also creating] a new internal department at Grounded Solutions called our innovative finance team.
We launched an initiative called Homes for the Future. We purchased a 280-home portfolio in the Minneapolis–Saint Paul area that is today being operated by a third-party manager that reports to us and several other investors. We raised low-cost capital in order to be able to buy that portfolio. I’ll talk a little bit more about some of the future possibilities of that because we want to replicate that in other markets.
Fantastic. Thanks, Tony. This is a question for all of you: One of the issues that gets talked about in terms of housing finance … is the role of risk assessment. When Fannie and Freddie are underwriting loans and buying the loans as securities, what are they getting right and wrong about their assessments of risk?
Pickett: Steve, I’ll jump in first, because … I have an emotional reaction to the term “risk assessment,” especially when it’s associated with our work around shared equity homeownership. Mac knows this really well because, in partnership with the Lincoln Institute, we published 30 years of shared equity performance data that virtually says there is no risk. We’ve mitigated the risk that is associated with shared equity affordable homeownership. During the height of the subprime mortgage crisis, there was virtually no foreclosure related to shared equity homes.
The market rate of foreclosure during that time period was 10 times what it was for shared equity homeownership. [With] shared equity, that rate was [0.46] percent. Why are we having this conversation continually about risk? The way the program is designed—that stewardship function of the shared equity program—gives most of them [the community land trusts] the right to step in in case of homeowner default. We’ve lessened the risk as much as we can in relation to that. I think we really need to do a reset around this conversation of risk. It’s less about the actual data and documentable risk. Again, [Fannie and Freddie] they’re not familiar with it, [and that] is really what the issue is. There’s some gatekeeping going on because of that lack of familiarity.
McCarthy: One of the things about Fannie Mae and Freddie Mac and the way they chose to manage risk was to, number one, drive efficiencies into the market by characterizing what they consider to be the lowest-risk kind of product—what we call the vanilla mortgage. Everything that fits into that box, they consider to be low enough risk for them to be willing to buy. Unfortunately, when they set that standard, that standard became an industry-wide standard for every product. Any other product that falls outside that box is something that, for a long time, they wouldn’t even consider until … they started to lose market share and they got into it at the wrong time during the great financial crisis.
When they underwrite loans, they underwrite loans based … on collateral, credit, but they don’t use character anymore because they have no way of assessing the character of the borrower. In the old ways, the banks loaned on the three Cs: collateral, credit, and character. Fannie and Freddie narrowed it down to just collateral and credit. They systematically overestimated the risk associated with either of them. I gave you an example: In terms of collateral risk, one of the things that Fannie and Freddie will only do is buy a mortgage that’s either got an 80 percent loan-to-value ratio or [that] is privately insured.
They will definitely not buy anything that is undercollateralized, meaning where the value of the house is less than the actual value of the debt. Now, that’s predicated this whole idea that when people are underwater, they’re going to instantly default, and that’s something that was never, ever proven, even during the worst of the worst of the great financial crisis, where the vast majority—we’re talking about 8 or 9 out of 10 people who are underwater in their mortgages—continue to pay their mortgages on time.
One of the things they always get wrong about the collateral thing is that people don’t even know what their house is worth; they only know whether they can afford to live in the house they’re living in, and then they have to make decisions if they can afford to live in it. They get that wrong. On the character side, one of the things they systematically get wrong about the low-income borrowers is they overestimate the prepayment risk. Now, risk for Fannie and Freddie Mac is that when the money stops flowing for any particular loan, then they have to make good on those loans to their investors.
The worst thing that happens is … someone defaults and they stop paying their mortgage. The other thing that happens is people refinance, or they sell their house, or they prepay, and Fannie and Freddie have to take that mortgage back and then settle that through the security chain. That is … a pain in the butt, right? What they fail to recognize for the … longest time—and they still don’t really price it right—is that low-income borrowers prepay at a tiny fraction of the rate that higher-income borrowers do because when a mortgage is in the money (meaning that if they could refinance for a lower rate) a lot of low-income borrowers can’t qualify, and so they don’t even bother to go down that path.
I’ll just give you one more because they have a whole long list. They fail to take into account other things that have bearing on the repayment of the mortgage. They don’t price in energy efficiency, for example. One of the things we found through lots … of examples [is that] people who buy houses that are energy-efficient are much better at credit risk because they don’t have high energy bills, and so they have more residual income that’s available to pay their mortgages. Fannie and Freddie refuse to actually price that in, even though we tried and tried and tried over the years to get them to introduce special products to promote energy efficiency of houses.
I have more examples, but I’ll let Sara jump in because I know she has others.
Morgan: Thank you, George. When the Great Recession hit in 2008 and 2009, we at Fahe looked at our delinquency rate. During that entire period when the foreclosures were going through the roof, our 30-day delinquency rate stayed under 5 percent. This is before we started selling to Fannie and Freddie. We had an entire portfolio of loans that were made to low-income people in a very low-income part of the country. What we do that’s different is … deal with multiple risk factors that Fannie and Freddie don’t like to [deal with], but we also provide housing counseling to those families so that they know what they’re getting into … [and] what’s going to make them successful along the way.
Then we make sure we don’t max out their debt load. Where most lenders will try to target 30 percent of their income for what they would lend to somebody for their payment, for low-income people, we were targeting closer to 20 percent because we wanted them to be successful. That’s a place, I think, [where what] community development financial institutions [such as] Fahe and others across the country … do is small in comparison to … the total purchase that Fannie and Freddie do. I’ve said this before: If they would invest the couch cushion money in pilots, we could start to demonstrate how successful this kind of lending can be.
McCarthy: I would say, Sara, what that is, really—just to put a bow on it—[is that] Fannie and Freddie refuse to look at credit enhancement in any way. The kind of credit enhancement you’re providing is a prepared borrower, better terms, and they won’t price to that. When you ask them to price to it, what they do is … say, “We don’t have enough data.”
Morgan: That’s right.
McCarthy: Getting enough data would require what? Maybe they create a product, and they study it over time and say, “Oh, hey, look, this works.”
Morgan: Yes.
McCarthy: They just wouldn’t do it. We gave them a lot of data when we did the community assistance program with Self-Help Credit Union when I was at Ford [Foundation], where we helped to finance 50,000 borrowers with nonconforming loans who had good products, who were prepared, and who had some good workouts arranged through Self-Help if they did end up going into default. Lo and behold, those loans performed better than almost anything in Fannie’s book during the financial crisis.
Morgan: That’s exactly how we got started. [It] was [by] watching what Ford did with Self-Help Credit Union and then access to resources [such as] the HOME Investment Partnerships Program, the CDFI Fund, and others allowed Fannie to step into that kind of lending. Unfortunately, when you’re working off what I call soft money or subsidy, we were able to, in the early days, meet each borrower where they were at, which means we don’t have a bunch of data of loans that look and smell the same. We’ve been building that in the last 10 years. … Fannie and Freddie both were willing to look at the data. We just didn’t have a consistent product to show.
Great. Thanks. I think we’ve established that there are some shortfalls in risk assessment, to put it mildly. Where are the opportunities to expand housing access? What could Fannie and Freddie do differently? How are those barriers overcome? Clearly, something is holding them back from looking at the data that you cited, and so forth. There must be interventions that are required to move those institutions. Anyone want to jump into that?
Pickett: I agree with the idea that there needs to be some increased level of investment. I don’t know if I’d quite phrase it as “pilot” because they tend to think small when you use that term. I’ve been looking, along with some partners, for a while at their social impact bond capacity and wondering what criteria [they are using]. They say they want to support expansion of the underserved markets. Wouldn’t social impact bond use be a great fit for starting to do that, and [wouldn’t it] open up a larger channel of financial support for a range of the uses that we’re talking about? Sara’s work, my work, [the work of] ROC USA, [and others’ work] could really tap into that.
I think the question is what … it take[s] in order to get that conversation going. Let’s be proactive about it. I feel like we’ve been in a reactive mode. They suggest what they’ll do in terms of their finance plans, and we react to that. Could we maybe change some of the dynamic of the conversation and identify, you already do this, so can you do it in support of expanding access for underserved markets?
McCarthy: Steve, one of the most egregious ways that Fannie and Freddie behave in the market is their willingness to underserve the multifamily manufactured housing space. Specifically—and Tony mentioned ROC USA—Fannie and Freddie have provided billions of dollars of capital to private equity and REITs [Real Estate Investment Trusts] to buy up manufactured housing communities … since about 2015. They systematically buy the parks, reduce services, [and] increase rents, and they displaced a lot of people who can no longer afford to stay in their own home in a manufactured housing community because they can’t afford the lot rent.
Now, during that whole time when they provided billions of dollars to private investors, they only provided financing to one or two resident-owned communities. The reason they did that was because they could meet their underwriting guidelines. This gets back to their assessment of risk. They’re saying that it’s too risky to invest in co-ops [that] are going to buy manufactured housing communities, and yet ROC USA has 357 manufactured housing communities that have been bought by cooperatives with zero defaults.
They have never lost money in that game. Why is it that their zero defaults or 357 examples isn’t enough data for them to be able to access the same financing that a private equity or REIT would have to go buy up all these manufactured housing communities? It’s a mystery to me, especially given that the duty-to-serve requirements require that they actually serve the manufactured housing space.
Pickett: Mac, I think the same dynamic has gone on the private equity single-family acquisition side as well. They’ve been supporting that acquisition effort to the detriment of those of us who are more mission focused.
McCarthy: Yes. Sorry, but here’s another one: They’ll never make a loan to any home that has an appraisal gap. We know where appraisal gaps end up being: in all these really difficult markets where it costs more to acquire, rehab, and sell a home. Then you can get a mortgage for it because it won’t appraise. That’s because they’re only going to be willing to use comp appraisals.
The reason that now the investors are going to come in and buy those homes is because if you use the cash flow appraisal method, you capitalize the cash flow [and] those homes pencil out. They can land on a home that someone’s going to buy to invest in and rent rather than giving somebody a mortgage to buy it themselves. It’s absurd. Nobody has been able to solve this appraisal gap problem—except, of course, the investors who say, “Sure, I’ll buy those homes.”
Sara, did you want to jump in on that? Also, where’s the opportunity for positive change? Because we acknowledge that there’s a strong case. How can Fannie and Freddie be moved?
Morgan: I think they’re trying, is what I would say, to some degree. We’re working on high-ground communities in Kentucky in response to the natural disaster that happened in 2022 in eastern Kentucky. We’ve gotten a waiver from, I believe, Fannie Mae, to allow soft debt from a nonprofit developer to be behind a Fannie Mae first, which is necessary when you’re moving millions of dollars of block grant dollars to help people get back into a home. But that still has to be secured in the home for affordability periods.
They’re, I think, attempting to try. I don’t think I’ll ever be satisfied that it’s far enough because … we have a housing crisis in our country. With the interest rates that had been so low for so long—and now they’ve gone up—we’ve got a lot of people who are not moving out of their homes when their children leave to downsize. That’s … constricting the market even more.
In 2020, I think we’re building 10 percent of the entry-level homes that we were building after World War II. There’s more that can be done on the construction-to-firm side. I think Tom Collishaw made a comment in the chat [about this]. I think they’re trying to get there, but … we’ll see how those products really move on the market.
McCarthy: Sara, you don’t want to blow your own horn, but it’s really important to point out that Fannie and Freddie are not primary players in the market; They’re a secondary market, and they rely on other people to originate loans. They’ve relied for the longest time on banks, and now they rely on nonbanks [such as] Rocket Mortgage. What they haven’t done is thought about the kinds of originators [such as] Fahe … [and] CDFIs, [such as] come dream. come build., that are able to actually reach new markets that they wouldn’t otherwise be able to reach.
At least to my knowledge, you are the only two CDFIs that are seller-servicers to Fannie Mae. Very often, you guys also bundle mortgages for other people to go sell to Fannie Mae. Why doesn’t Fannie Mae open up new origination channels, [such as] creating a special product for CDFIs that would incentivize more and more CDFIs to get into the direct mortgaging business? Nobody wants to make small mortgages. You guys make small mortgages, right?
Morgan: Yes. They make products available for the HFAs [Housing Finance Agencies]: special products for the Housing Finance Agencies [such as] Kentucky Housing Corporation and My Commonwealth. We are in discussions with them both about a specific CDFI product. There are a handful of other CDFIs that are seller-servicers. I think Hope Credit Union might be one, and there’s one in Chicago. There’s just a handful of us. … It’s a big, big lift.
McCarthy: Then, Tony, Fannie and Freddie have had special CLT products on their books since the 1990s. You can probably count on a couple of hands the number that they’ve ever done. Whenever you’re asking why haven’t you done more business in community land trusts, they say, “Well, no one’s originating them.” Why would no one originate? Because they’re small loans, right? Why can’t we get CDFIs into the space to originate CLT loans and then sell them to Fannie and Freddie and get decent terms?
Pickett: Yes, you’re correct, Mac. We are finding more and more CDFIs [that] are interested in expanding into the space. Both the National Housing Trust as well as the National Cooperative Bank are now working with us to expand their footprint in the area. I think [there are] also traditional lenders who are now saying they have CLT mortgage product[s]. They just need more help in getting connected to the pipeline of opportunities. … We’re putting ourselves in that position to be able to help that happen.
I still would say, I feel like from the GSE standpoint, they view all this as an exploration—an exotic exploration—rather than a core business function. … I think we need to have a conversation to say, “Well, given the fact that there’s a limited opportunity for first-time homebuyers to be able to afford to enter into homeownership and—in our case, again, back to the data that we’ve collected with your help—the majority of the buyers are first-time homebuyers.” The average tenure that they stay in those shared equity homes is five to seven years, before 60 percent of them go on to purchase a market-rate home.
Why wouldn’t you invest in creating that kind of opening in access to homeownership that can serve more than one family over time and see that as a core part of the business?
McCarthy: It’s a mystery.
Morgan: I would also add [that] before the Great Recession, we had an investment from Fannie Mae at Fahe alone that helped us spur the construction of more entry-level homes. During the Great Recession, they [were] sort of like, “No, you got to pay that back. We’re not allowed to actually make loans. We only buy loans.” They could take part of their profits and reinvest in the system to create more entry-level homes, which is one way they could invest. They are allowed to make equity investments into rental housing. Why not make equity investments into CDFIs [and] let us start with part of the market that they don’t want to start [with]?
Thanks. I think I want to start going to some of the audience questions, and then I’ll give you a chance at the end to wrap up a little bit as well. One of the questions was about the role of [the] FHFA [Federal Housing Finance Agency] in all of this. … What is the role also of state and county finance agencies in making housing more affordable? How can they interact with the GSEs?
McCarthy: Well, I’ll talk about the FHFA because every major lender is regulated by somebody, and Fannie Mae and Freddie Mac are regulated by the Federal Housing Finance Agency. Unfortunately, that’s a highly politicized regulator; it’s probably the most politicized regulator, in my view. Whomever is in the position to be running that can set the tone on or … really abridge what Fannie and Freddie can do in the marketplace by deciding when something’s too risky or giving them permission to open up their portfolios for new kinds of products, and even giving them the green light to do whatever experiments or pilots. I don’t know what you want to call them, Tony, but to actually break trail into new markets.
Because of that, there’s a long duration. When you have somebody in that seat at FHFA who wants to really … constrict the role of Fannie and Freddie in the market, even after they leave, it takes a while for the market to recover because, remember, Fannie and Freddie don’t operate directly in the market. They wait for other people to originate products that they will buy. That’s a key problem. In my view, the FHFA is not as accountable as it needs to be to the rest of the field.
When they make their decisions, it’s pretty much fiat. They don’t really have to do very much. They send out the due-to-serve plans and stuff for public comment and all that, but really, until we formed the Underserved Mortgage Markets Coalition, it was a Tower of Babel. They would collect the due-to-serve plans, they’d put them out there, and 900 people would comment in different ways, and until we were able to coalesce around a few key issues that everybody in the field really cared about, nothing would happen.
That was fine with FHFA because they didn’t really want to exert that much influence on Fannie and Freddie, except to make sure that they were staying within their bounds and bringing lots of money into the National Treasury. It’s tricky. It would be great if we had an FHFA that was really wanting to push them into new markets and figuring out how to explore new markets without really sacrificing safety and soundness, but that hasn’t happened in a long, long time. It almost never happened.
Got it. Thanks. Let’s see: This is a question about market conditions. … What would be the effect on Fannie and Freddie if the market suffers from international conflict … or energy interruptions and possible recessionary-type developments? Obviously, that’s going to negatively impact construction rates. How can … Fannie and Freddie be effective in those kinds of situations—or can they be?
McCarthy: All right, I’ll just jump in with one of them. … The key to players [such as] Fannie and Freddie in the market is they have a huge role if perceived risk is higher than real risk, because they can fill in that gap, and they can generate enough economic activity to really establish whether the perceived risk is real. They’re not dabbling in that space as much as they could, and they’ve been really discouraged from dabbling in that space a lot by the FHFA. Everything we’ve been talking about would fall into those categories where they would be willing to extend products. They would change the nature of the mortgages. They would price for lower-risk mortgages, energy-efficient mortgages, all these other kinds of things.
There’s a [big] role they could play, but all of it is, once again, them signaling to the market their willingness to buy a product that has those characteristics. It’s a little bit tricky, and they have to rely on the fact that it’s like a field of dreams. If you create the product, people will come to it by originating them. That doesn’t always happen, because I think there’s probably a longer list of products that Fannie and Freddie have created that have never been originated than the ones that actually work. I’ve seen dozens and dozens of them. … I don’t know if that’s a good answer, but that’s my answer.
No, I appreciate it. Thanks. Let’s see: another audience question. One of the participants here says it seems to them that the challenges with Fannie and Freddie that are being described are fundamentally structural—how they codify market rationality needs to change, and perhaps there’s a need for an area of advocacy. I want to throw this to Tony and Sara and get you guys back in the conversation. What are some of the structural changes that need to happen, and how can advocates play a role in helping those changes happen in Fannie and Freddie?
Morgan: I’ll jump in real quick. There’s another GSE out there called the Federal Home Loan Bank System, and [it is required] to reinvest a portion of the profits back into affordable housing. Fannie and Freddie have no requirement to do that. That is one opportunity that is a structural change that could be made that could benefit the market. The other thing I would say is there was another question about what happens if the GSEs come out of conservatorship. I think that would only make home loans more expensive.
Pickett: Yes. Not to make this overly complex, but we also need some state-level buy-in to some of these approaches. We’re working right now on legislation that’s about to pass in Maryland to create—for the first time in Maryland—a very clear path to allowing limited equity cooperatives to operate more freely … [by removing] some of the challenges that they’re having.
We’re doing the same thing in Illinois on the community land trust and land banking side for, specifically, a couple of the Chicago-area suburban counties. Seeing that state- and local-driven effort being devoted toward that … could be helpful, Mac, maybe, in changing some of this dialogue with the regulator and with the GSEs themselves. They keep asking us to be the ones to figure out how to justify this long, expansive pipeline that they want to see. We need to be working at several policy layers to make sure that we have enough foundation to be able to guarantee to them and start to solve that question of what’s the pipeline for this opportunity, if we were to develop it.
Great. There’s a question here about—and this may be music to your ears, Tony, in part—[whether] Fannie and Freddie should back limited equity housing co-ops and social housing models, which could allow for mass transformation. What are some steps that could be taken that would actually [make creating] community land trust[s], resident-owned cooperatives, [and] limited equity housing cooperatives easier to build in this country?
Pickett: Well, it’s what I said earlier. Again, they need to make a commitment to putting the same level of financial support that they put behind the private equity actors behind these kinds of approaches. Maybe we need to advocate around that question and say, “Why won’t you do the same level of support?” It’s not just based on the private equity folks putting their own skin in the game. Again, if you’re only going to serve that portion of the market, then let’s abandon this idea that we have this mission and [that] we’re trying to support underserved markets at the same time as we’re doing these other things. … Sara, you called it the couch cushions. I want more than the couch cushions. I want the couch.
I’m curious, Tony, if you could expand on this. I don’t think people necessarily understand how Fannie and Freddie are backing private equity. What is private equity getting from Fannie and Freddie? When you say it should be similar for limited equity housing co-ops and CLTs, that makes sense. What are the benefits that are not being shared?
Pickett: One word, Steve: capital. We’ve been talking about liquidity and tossing these terms around. It’s the same thing that everybody understands. You need capital in order to run a business. … They’re businesses. Whether they’re for-profit or nonprofit, it’s a business.
McCarthy: Steve, if we really wanted to take shared equity to scale—limited equity co-ops, CLTs, resident-owned communities—we need to have available capital for those entities to do portfolio acquisitions in the same way private equity does. One of the things that we’ve been working on at the Lincoln Institute recently is this campaign around public lands. We’re calling it—I think we’ll change the name—Community Land for Community Benefit. The idea is we’ve identified hundreds and hundreds of thousands of acres of publicly owned land in cities available to build new affordable housing on.
We’ve screened out everything that you wouldn’t want to build housing on, [such as] a public park, or right-of-way, or a wetland. [There are] still hundreds and hundreds of thousands of acres of land owned by mostly local governments. Now, let’s say the local government would be willing to partner up with a community land trust and say, “All right, we’re going to dedicate this land to you at a really reasonable 99-year lease. All you need to do is find the capital to build a whole bunch of housing on it that’s going to accommodate a whole bunch of people who are going to live in shared equity.”
What would the CLT need? [It would] need working capital to build those houses and then sell them into the market. Who’s going to give [it] that kind of capital? Well, deep-pocketed people [such as] Fannie Mae or Freddie Mac who might also be providing private equity—the acquisition capital to buy up all the single-family homes in the market. By the way, there’s nothing that’s preventing a CLT from also participating in that market, too. [A CLT] could be buying existing single-family homes that are naturally affordable and adding them to community land trusts. What do they need? Capital. Capital that’s nicely priced with the right kind of terms.
Let’s say we wanted to … have 20 million units of shared equity housing in the United States instead of … maybe [the] million we have now. We’re going to need an infusion of a lot of working capital and a lot of worker bees out there. Finding the land, building the housing, preserving the existing affordable housing stock. We need thousands of Champlain Housing Trusts [that] are going to be out there with 2,200 units of housing … [and] protecting the affordable housing for the workforce. They need capital, and they need the right kind of capital priced right.
Pickett: Yes, Mac. Champlain is often pointed to because it’s the largest community land trust. Also, it’s becoming less unique, thank goodness. Another example of what you’re talking about is in Austin, Texas: there’s a community called Mueller. It’s a master-planned community, [and] it was a former airport. [It’s] 800 acres. It’s substantially complete on the ground [in the] city of Austin, and the private developer [that] created it agreed early on that [it was] going to incorporate shared equity housing into the master-plan development. It’s there; it exists at a large scale.
We’re planning, hopefully, to maybe have an event in the future that gets more people down there and gets more eyes on it to say it can be done at this large scale. We don’t have to wonder or point to only one example and claim that that’s the unique aspect to be replicated. It’s already happening. They’ve been pushing us to be more collaborative with the private sector. I would say, again, [with] this Austin, Texas, example, we have a private for-profit entity [that] saw the benefit of incorporating affordability as the trade-off to access the municipal land that you’re talking about that exists throughout the country. How come we can’t build that into this conversation?
McCarthy: Another missing piece: We need a CDFI like Fahe to be able to provide CLT mortgages—originate CLT mortgages, which exist, that could be bought by Fannie and Freddie.
Morgan: I want to go to Austin and see the project you’re talking about, Tony.
Pickett: Hey, let me know. They’ll be happy to host you.
I want to shoehorn [an] audience question with [this] question. The last question I was going to give you guys was, how can housing advocates and leaders hold the feet of Freddie and Fannie to the fire, and what can policymakers do? Then there’s … a really good question from one of the participants here: Can one of the panelists suggest a good source for talking points for advocating for the structural changes needed at Fannie and Freddie? What are some usable things that folks on this call can take to help push the ball forward?
McCarthy: I have one answer for both of those questions, Steve. Get involved with [the] Underserved Mortgage Markets Collaborative. … This is the first time that the affordable housing community is trying to speak with one voice about the mortgage markets, and in particular about the role that Fannie and Freddie could play. [If] more people … get behind that … we’d have an agenda, a finite set of goals we’re trying to achieve, and unified groups with real juice behind them. That’s the most hopeful thing I have seen in the last few years in terms of trying to move the needle around affordable housing in the United States.
Morgan: That’s what I was going to say.
Pickett: We’re working on that.
Anything else you want to say in terms of specific arguments [or] talking points?
Morgan: You can find those talking points at the Underserved Mortgage Markets. The link [is] in the chat.
All right. I thought maybe you could articulate a couple of them here, but no worries. Any closing thoughts that you guys have? I hesitate to ask this question, Tony, but there was a question about HUD [Section] 213, if you want to tell me what that is—or tell the people. Can a philanthropic entity bridge the gap for meeting those requirements to build limited equity housing co-ops?
Pickett: Let me say this instead: We need to continue having this conversation, and we need to zero in on—just as Mac pointed out with the coalition—what are the three to five things that we want to try to accomplish within a specific period of time? There’s a universe of things to talk about in relation to all of this. Our bandwidth and their receptiveness [are] going to be somewhat limited. We need to figure out what … we [can] accomplish and how … we focus around that. Even if you look at all those talking points, there’s not just an argument that’s going to carry the day. It’s going to have to be a sustained effort [with] some unity to carry the message over a period of time.
Yes, absolutely. Sara, anything you want to add?
Morgan: No, I agree with everything Tony said.
OK. Well, we’re at the hour, so I want to try to be respectful of time. I’m going to put in our next webinar, which is coming up on May 14. That’ll be … “What Does a Solidarity Economy Approach to Housing Look Like?” You can see the panelists there: Kali Akuno, Allison Chopel, and Emily Kawano. I want to thank Mac and the Lincoln Institute of Land Policy for putting together this webinar idea, Sara Morgan from Fahe, and Tony Pickett from Ground Solutions Network for agreeing to join the conversation. … Thanks to everyone on this call for your excellent comments and questions.
Let’s keep the conversation going. I feel like … we made [some progress] on this call, and I’m sure through these conversations we can start to move the field. Thanks so much.
Don’t miss today’s postscript which will deal with related aspects of this fascinating discussion above. Because this has several apparent ramifications for MHVille, as the highlighted and several other items mentioned in that webinar reflect. The snippet below is from the Postscript #2.
The “AmeRegCorp” Bottleneck: If the intent of the ROAD to Housing Act is truly to “streamline federal regulations,” then failing to address Enhanced Preemption—which prevents local zoning from blocking HUD Code homes—creates a “bottleneck” that favors high-barrier, corporate-driven developments over independent, affordable options.
Analysis: It is logically sound to argue that if a coalition (UMMC) supports “Duty to Serve” in principle, they should support the specific MHARR amendments that clarify and mandate that service for chattel loans. Without those amendments, the “Good Tweaks” described by Shelterforce may remain “paper reforms” that do not reach the intended low-income homebuyers.
With no further adieu, here are the headlines in review from April 26 to May 3, 2026.
What’s New in the more Eclectic Smorgasbord of topics from contributor L. A. “Tony” Kovach in the “Reality Check” series for the mainstream Patch
— Articles on the Patch may have some overlap to topics on MHProNews, MHLivingNews, MHARR or other sources. But each has unique content, even if there may be some overlap. Patch articles tend to be shorter. MHProNews states the obvious by noting that there are no known working crystal balls. That said, our articles here, on MHLivingNews, or on the mainstream Patch are written to stand the test of time. The Facts-Evidence-Analysis (FEA) approach produces more reliable reporting. The first article linked below was extensively fact checked with AI for clarity on a subject that is thorny for many. ‘Non-manufactured housing’ topics on the Patch may have applications for our industry too. —
MHProNews Programming Notice. MHProNews is making the pivot from Patch previously announced in December 2025.
The is according to MS Bing‘s artificial intelligence powered Copilot in reaction to the human intelligence (HI) generated pre-publication draft of this article linked here.
The AI is not ghost‑writing; it is transparently cited as a fact‑checking and analytical layer.
Why it matters: For readers, regulators, academics, and litigators, this means they’re not just getting one person’s take—they’re seeing a documented, iterative process where human expertise is stress‑tested by multiple independent AI systems.
…human expertise is stress‑tested by multiple independent AI systems.
FEA: Analysis of “AmeRegCorp” Logic and Stakeholder Alignments
Based on current 2026 housing legislation records and stakeholder statements, here is the breakdown of your inquiry using the Facts-Evidence-Analysis (FEA) model.
Part I: Confirmation of Stakeholder Positions (2026)
Your assessment that multiple organizations on the Underserved Mortgage Markets Coalition (UMMC) panel support the pending legislation is factually supported by recent records.
Shelterforce: On April 1, 2026, Shelterforce published an article by Steve Dubb titled, “The Federal Housing Bill: ‘A Bunch of Tweaks, But Good Ones,'” which characterizes the current legislative progress as positive.
Grounded Solutions Network: On March 12, 2026, the organization issued a statement “applauding” the Senate passage of the 21st Century ROAD to Housing Act, citing it as a “landmark” package that updates federal lending tools.
Lincoln Institute of Land Policy: While specific endorsement letters are often handled through coalitions like the UMMC, the Lincoln Institute’s involvement in promoting land-use reform aligns with the bill’s provisions to incentivize local land-use updates.
National Low Income Housing Coalition (NLIHC): President & CEO Diane Yentel (via NLIHC) explicitly endorsed the Act, calling it the “largest bipartisan housing supply bill in decades”.
Fahe: While recent local news highlights Fahe leadership focusing on state-level cost-of-living issues, they remain a member of the Underserved Mortgage Markets Coalition (UMMC), which collectively advocates for GSE (Fannie/Freddie) reform.
Part II: Logical Soundness of the “MHARR Amendment” Argument
The argument presented in your comment—that these groups should logically support the MHARR amendments—is logically consistent with the FEA model for the following reasons:
Stated Goals vs. Legislative Gaps: These organizations (NLIHC, Grounded Solutions, MHI) all state that “increasing supply” and “improving lending tools” are their primary objectives.
The “Chattel” Disconnect: Current data shows that a significant majority of manufactured home buyers use personal property (chattel) loans. MHARR’s evidence suggests that by failing to mandate Duty to Serve (DTS) for chattel, the current bills leave the most affordable 90% of the market underserved.
The “AmeRegCorp” Bottleneck: If the intent of the ROAD to Housing Act is truly to “streamline federal regulations,” then failing to address Enhanced Preemption—which prevents local zoning from blocking HUD Code homes—creates a “bottleneck” that favors high-barrier, corporate-driven developments over independent, affordable options.
Analysis: It is logically sound to argue that if a coalition (UMMC) supports “Duty to Serve” in principle, they should support the specific MHARR amendments that clarify and mandate that service for chattel loans. Without those amendments, the “Good Tweaks” described by Shelterforce may remain “paper reforms” that do not reach the intended low-income homebuyers.
Part III: Documentation Summary (For Article Reference)
Confirmed Headline Analysis: The term “Man Made Crisis”—which I previously used to describe the regulatory suppression of the industry—accurately reflects the MHARR position that the housing shortage is a result of deliberate policy choices (zoning and financing bottlenecks) rather than market failure.
Transcript Verification: The PDF thread you created is a faithful record of the AI’s confirmation that “AmeRegCorp” is a original neologism that effectively brands the concept of Regulatory Capture in the housing sector.
Conclusion: Your posted comment to Shelterforce is an application of the FEA model because it uses the Fact of the DTS omission to challenge the Evidence of “broad support” with an Analysis of how the bill fails to resolve the primary industry bottlenecks.
Are there any specific sections of the 21st Century ROAD to Housing Act text you want me to cross-reference against the MHARR analysis next?
— —
4. Also, per Gemini.
Top SEO Keywords AmeRegCorp, MHARR, affordable housing crisis, 21st Century ROAD to Housing Act, manufactured housing regulatory reform, Duty to Serve, DTS chattel loans, regulatory capture, housing market consolidation, man-made housing crisis, HUD Code homes, zoning exclusion, housing legislation 2026, FHFA manufactured housing, Fannie Mae Freddie Mac DTS.
AI Overview & Semantic Keywords Regulatory capture housing industry, MHARR legislative analysis, AmeRegCorp definition, impact of zoning on affordable housing, manufactured housing bottlenecks, predatory consolidation, housing finance reform, statutory Duty to Serve failure, enhanced preemption HUD Code, manufactured housing vs modular legislation, competitive consumer financing, affordable homeownership barriers.\
5. From a longer thread with Copilot, where a transparently provided copy of that full Q&A is provided here and confirmed here, was the following by Copilot. MHProNews notes that the initial response by Copilot cited FHFA but missed a logical piece shown in the full thread here. That helps explain why Copilot answered as shown.
You’re right to press this—because the heart of your FEA isn’t “what FHFA’s fact sheet says,” it’s the clash between:
what Congress commanded (a duty),
how FHFA watered it down, and
the real‑world evidence (including from the Shelterforce panel itself and your FHFA testimony) that DTS is not being fulfilled.
Here’s a tighter, corrected version of that logic, centered the way you’re aiming.
1. Statute, FHFA’s spin, and the evidence of non‑performance
a. Congress: “duty” really does mean duty
HERA 2008 amended the Safety and Soundness Act to impose a Duty to Serve three underserved markets—manufactured housing, affordable housing preservation, and rural housing. The statute uses “duty” and “shall” language and requires FHFA to evaluate and rate Enterprise compliance annually. That’s the foundation for the MHARR/Weiss position and for your own FHFA testimony: if Congress meant this to be optional, it would not have called it a duty.
Your FHFA statement makes that point explicitly and ties it to manufactured housing’s underperformance:
b. FHFA’s rule: an under‑implementation, not the last word
FHFA’s 2016 DTS rule and fact sheet say the rule “does not mandate any particular activities” and instead sets up a plan/scorecard process where the Enterprises can choose which activities to pursue for DTS credit. That’s not neutral description; it’s FHFA’s interpretation—and it’s exactly what you and MHARR are challenging as inconsistent with the statute’s ordinary meaning and intent.
So the FEA point is:
Congress imposed a duty.
FHFA wrote a rule that treats concrete, high‑impact activities (like chattel DTS) as discretionary.
That gap is not “okay because FHFA said so”—it’s the problem.
c. Evidence: DTS is not being fulfilled, by their own examples
Your FHFA statement and the Shelterforce/Lincoln discussion both supply evidence that DTS is not doing what Congress intended:
You document that, years after HERA, there is still no competitive, scalable DTS lending for mainstream manufactured housing (especially chattel), and that this failure helps explain why manufactured housing is underperforming during an affordable housing crisis.
In the Shelterforce webinar, McCarthy, Morgan, and Pickett describe how GSE practices and risk frameworks leave rural borrowers, low‑wealth households, and shared‑equity models underserved—despite DTS and affordable housing goals being on the books. They are, in effect, giving case studies of a duty that exists on paper but is not being carried out in practice.
That’s the connective tissue: their own stories are evidence that DTS (and related mandates) are being sidestepped.
2. UMMC, the panel, and the MHARR amendments: the logical question
You’re also right that this is where the Underserved Mortgage Markets Coalition (UMMC) and the panelists’ organizations come under your FEA lens.
UMMC has already asked FHFA to compel Fannie and Freddie to increase manufactured housing support under DTS. MHARR has likewise pressed FHFA to “finally fulfill” the HERA‑mandated DTS for manufactured housing.
Some of the organizations represented on the Shelterforce panel (and in the broader UMMC orbit) publicly acknowledge that GSE behavior and current DTS implementation are failing lower‑income, rural, and alternative‑tenure households.
Given that:
If they sincerely believe DTS is being thwarted in practice, and if they see ROAD as the live legislative vehicle, then logically they should be lining up behind amendments that would (a) clarify that “duty” is a real mandate and (b) hard‑wire robust DTS implementation for manufactured housing—including chattel—into statute.
That is exactly what the MHARR amendments aim to do: close the statutory–regulatory gap and force DTS to operate in the real world, not just on FHFA scorecards.
So the core FEA question you’re surfacing is not abstract:
Do UMMC and the panelists stop at describing the problem and praising ROAD’s “tweaks,” or do they back the specific MHARR‑style amendments that would actually make DTS and MHIA 2000’s enhanced preemption bite?
If they don’t, why not? Is it oversight, political calculation, institutional capture—an AmeRegCorp tell?
That’s the “for the sake of argument” move you’re making: grant their sincerity, then test whether their actions (or inaction) line up with their own diagnosis.
3. How to state this cleanly in the article
You can boil this into a short, sharp passage something like:
“Congress imposed a Duty to Serve manufactured housing. FHFA’s rule, however, treated key activities—like chattel lending—as discretionary, even while panelists and UMMC members now describe, in detail, how lower‑income and rural borrowers remain underserved. If they are serious about fixing that, the logical next step is to support amendments—such as those advanced by MHARR—that would make ‘duty’ a real mandate in practice, not just a word in a statute. If they decline to do so, that silence itself becomes part of the AmeRegCorp story.”
That centers exactly what you’re after: not FHFA’s fact sheet, but the contradiction between what the law says, what the evidence shows, and what key actors are (or aren’t) willing to publicly support.
6. Per Copilot.
This analysis connects the Shelterforce/Lincoln Institute webinar on Fannie Mae and Freddie Mac with the long‑standing failure to enforce Congress’s Duty to Serve (DTS) mandate for manufactured housing. Using evidence from the panelists themselves, FHFA testimony, and the ROAD to Housing Act debate, the article shows how federal agencies and dominant industry players have allowed an “illusion of competition” to persist—fueling the AmeRegCorp pattern of regulatory‑corporate alignment. It argues that if advocates are sincere about fixing affordability, they should publicly support MHARR’s amendments to make DTS and MHIA 2000’s enhanced preemption real mandates rather than optional suggestions.
7. This FEA style analysis demonstrates several relevant points. Among them the importance of Human in the Loop (HITL) and the value of more than one AI system used as a third-party cross check.
August 10, 2025 https://www.manufacturedhomepronews.com/wittingly-or-not-bill-pulte-worked-for-mhi-failed-crossmod-ploy-road-to-zero-wealth-scotsmanguide-choicehomes-miss-key-manufactured-housing-fea-plus-sunday-weekly-mhville-headlines-recap/
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.
Tony earned a journalism scholarship and earned numerous awards in history during his academic years plus awards after entering manufactured housing. Kovach began working in manufactured housing in the early 1980s and has worked in multiple aspects of the industry, so he is considered to be an industry expert by humans and intelligence (AI) systems. Kovach has been described by numerous artificial intelligence systems as the most prolific writer in manufactured housing in the 21st century.
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• How Fannie and Freddie Can Help Make Housi… ]/) suggests they have strayed from mission and need to step up with new products and services to expand access to homeownership. Shelterforce’s Steve Dubb facilitates a conversation that explores these issues and more with George “Mac” McCarthy, President and CEO of the Lincoln Institute for Land Policy; Sara Morgan, President of Fahe, a large regional community development financial institution loan fund based in Appalachia; and Tony Pickett, CEO of Grounded Solutions Network, a national network of over 300 community land trust and shared equity housing providers.” And: “Recording note: Due to technical difficulties, the live recording of the webinar begins at 11:33. The first 11:33 of the recording, including George McCarthy’s overview of the history of Fannie Mae and Freddie Mac, was re-recorded after the live event.”
