“Smoking Gun” Once Secret “Damning” Manufactured Housing Institute (MHI) Letters Obtained – Reveal “Betrayal” of Trust Undermine MHI’s Claims; plus Manufactured Home Stocks, Markets Updates

Smoking GunOnceSecretDamningManufacturedHousingInstituteLogoMHIlogoLettersRevealBetrayalTrustUndermineMHIclaimsPlusManufacturedHomeStocksFactsAnalysisMHProNews

A pair of photocopies of documents have been obtained from the U.S. Department of Energy (DOE) by MHProNews. The first of these documents is on the letterhead of the Manufactured Housing Institute (MHI), as will be shown below. These two documents are apparently signed by an MHI official on behalf of that trade group and shed light on long-festering dueling claims about that nonprofit’s reliability and motivations. Those claims include the notion that MHI has been posturing as operating on behalf of “all segments” of “the manufactured housing industry.” Critics of MHI – as these documents apparently give substantial evidence – accuse the Arlington, VA based trade group of slyly operating on behalf of a limited number of larger corporate interests, while posing to the balance of the manufactured home industry’s consumers, public officials, independent retailers, communities, suppliers, and producers that they are working “for all” segments of the profession. MHI supporters, of course, deny such allegations. Once the manufactured housing industry specific realities and frameworks are outlined and unpacked, there are good reasons to see these two documents as fresh “smoking gun” evidence of betrayal of trust that could involve violations of federal laws.  They may lead in time to concerns for board members and staffers alike, as well as to those who may have mistakenly trusted operations and individuals connected to MHI.

This report and analysis will begin to explore elements of the first of those two documents obtained from DOE and will in separate reports examine their respective significance.

To understand the evidence, someone must first understand what makes manufactured housing unique and how that those distinctive qualities are important to a broad cross-section of Americans, even if most do not realize it. This fresh “Smoking Gun” evidence connected to MHI obtained from the DOE will then be followed by a link to the Manufactured Housing Association for Regulatory Reform (MHARR) most recent media release on the DOE rule, and finally will conclude our business daily broader and manufactured housing specific market reporting.  The latest MHARR DOE report will be unpacked at a different time by MHProNews.

To Understand the “Smoking Gun” from MHI, One Must Grasp the Basics About Manufactured Homes

Because others outside of manufactured housing will be reading this report, it is necessary to first set the stage for this issue. Only with a proper factual foundation can these revealing remarks by MHI be grasped. Thus, one must first understand and/or be reminded of the entire premise of modern HUD Code manufactured housing. So a focused review of manufactured housing will prove essential.

It is largely agreed that a manufactured home has appeal due to cost savings over other forms of construction while maintaining performance that compares favorably with conventional building plus offers strong consumer safeguards.

With the above in mind, these insights will help in the examination of the importance of the MHI documents.

  • As a practical matter, for a variety of reasons, if manufactured homes cost more than conventional ‘site building,’ there would be little or no market for manufactured housing.
  • If the cost difference between conventional housing – perceived by millions, right and/or wrong, to be ‘better’ than factory building – was nominal, sales would be too.
  • The evidence for those bullets are found in modular construction sales data, as both HUD Code manufactured homes and modular construction emerge from a factory. Sometimes a factory produces both modular and manufactured housing, so for clarity, that is not meant as a slam on modular building. Each type of building serves several useful needs. Both modular and manufactured housing arguably ought to be more common, not less so. That noted, when modular home building volume is only a fraction of manufactured housing totals, and manufactured housing in the Berkshire Hathaway era is only a fraction of what our industry once produced in the late 1970s-through 2000, that tells us much about the market potential for each product niche.
  • Let’s note too that there have long been various types of prefabricated housing, or prefabbed housing components, used in conventional construction. Manufactured and modular building have influence site builders, and site builders have influence factory builders too.

Once those factual insights are noted, several facts make more sense in that context. As an example, note that this manufactured homeowner brags about the value he has compared to far more costly conventional building in a home that is comparable in quality and features.


Note: costs on all housing have risen since the video above was produced.

Surveys and experience alike reveal that the savings that manufactured housing offers over conventional building is a core magnet for attracting consumers. Of course, consumer safeguards and performance are in that mix. Once this simple reality is understood, it is worth briefly note on a different topic for another time that the methods commonly used to engage the public by manufactured home marketers and sellers are often flawed, as our firm’s consulting side has demonstrated in several cases in various markets and as claims by others reveals too. Specifically, as MHProNews has previously reported, the very high levels of engagement claimed by sites like MHVillage and ManufacturedHomes ironically reveal just how little impact pretty pictures, 3D tech and sharp websites have on the public as they are currently used. That is self-evident, when pondered. If tens of millions of claimed visits are occurring on their sites, that should reasonably translate into hundreds of thousands – if not millions – of new manufactured homes sold. But are years of data reveal, that is obviously not the case. The industry is only selling at about 30 percent of its last high water mark (details in first link, below).




That noted, if manufactured housing is to thrive in a manner more like previous sales levels or in ever superior production demand to those enjoyed previously, the factors that follow will be reasons for such a surge.

  • Suffice it to say that be it “shade and shelter” style of manufactured housing or more ‘residential’ style of construction – i.e.: more akin to the look of conventional building – each has its own niche that could be numerous times larger in sales volume than it currently is experiencing.

But the opposite is also true.

  • If manufactured homes, no matter how nice or appealing, approached a similar price point to conventional building or modular building, then sales would obviously be harmed.
  • That in a nutshell explains why the Manufactured Housing Association for Regulatory Reform (MHARR) has fought tooth and nail, so to speak, to stop the DOE rule.
  • By contrast, while MHI in fairness also claims to care about cost impacts, the first of two documents below will apparently reveal once more a more subtle agenda. That obscured agenda stands in contrast to MHI’s more public stance and comments shared to the broader industry.

Summing this segment up, the battle over costs and standards – which are obviously connected – explain why the DOE energy rule battle for manufactured housing is so important.

If energy or other conventional building standards are superimposed on manufactured housing that weakens our industry’s advantage, sales will be impacted for reasons noted.

That noted, a key part of the premise of our profession’s products is precisely that they are built to ‘performance’ standards vs. ‘prescriptive’ standards.

To illustrate this in a crystal-clear manner, let’s briefly hypothetically ask:

  • what matters more to a consumer? Numbers and nails? Or is it performance on matters of safety, durability, energy efficiency, warranty periods, resale value, etc.?
  • Clothes made in factories were similar and lower cost than clothing made by hand or by a particular seamstress. Manufactured clothing far outsells tailored clothing. That has been true for decades.
  • So long as a manufactured home performs in a similar manner as conventional site building or modular building (noting that modular building could be defined as housing built in a production center that has the same standards as conventional building in a given state and must meet the same codes), that performance and space at a bargain value are what consumers are buying with a manufactured home.

With that backdrop, the first letter on MHI letterhead involving the DOE energy standards arguably exposes that MHI has been telling the industry’s rank-and-file members something quite different than what they have communicating to DOE and to others interested in the energy standards. That will be then be contrasted with the Manufactured Housing Association for Regulatory Reform (MHARR) has done for years on this same issue.


With the Backdrop Set, On MHI Letterhead to DOE, the Following “Smoking Gun,” Followed by How This Revelation Fits Into the Bigger Picture.

The entire MHI document will be released in the near term. But for now, this photostatic copy obtained from a source at the DOE will be used as evidence of thetainted process that has apparently been at work at MHI for over 7 years on this issue. A series of relevant and “damning” pull quotes from this letter will follow.

Screen capture of segments of MHI letterhead and MHI VP Lois Starkey signature. 

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MHI and its members would be delighted to participate and support such an effort.” That is a key line from the March 14, 2014 letter on MHI letterhead. What effort involving DOE is MHI saying they would be “delighted” to participate in? More on that in a planned follow up, but a key line is this “I [MHI VP Lois Starkey] am writing to respectfully request that the Department of Energy consider a negotiated rulemaking for the establishment of energy efficiency standards for manufactured housing.”

In its own words and at face value, MHI is asking for new and costly energy standards that MHARR has consistently said would cost millions of Americans the potential for owning a manufactured home. In other times, MHI themselves admit that the planned regulations would be costly and harmful to new home sales.

Thus, this request by then MHI VP Starkey would on the surface make no sense for anyone who wants to sell more HUD Code homes. The reason for that has been laid out above. But additionally, it would make no sense for those who would be ‘priced out’ of manufactured housing, per NAHB’s own data on that point.


The apparent rational for this MHI “request” to DOE will be further unpacked below. But suffice it to say for now, that this benefits only a few ‘insiders’ that can withstand lost sales, while harming the interests of others, including consumers who would be priced out due to policies that would harm the value proposition of manufactured housing.

The MHI letter also says: “We strongly support efforts to engage the Department of Housing and Urban Development (HUD) and the Manufactured Housing Consensus Committee (MHCC). The MHCC is the Federal Advisory Committee established to recommend all changes to the Manufactured Housing Construction Standards and Regulations.” Also, “As you know, HUD has regulatory authority over the development and enforcement of the Manufactured Housing Construction and Safety Standards, including energy efficiency standards.”

Other statements are included in this MHI letter that they might attempt to argue will show their good faith in the above. In fairness, let’s consider that possibility for a few moments.

  • If this was a good faith effort, why is this document not found on the public side of the MHI website?
  • Additionally, at that time, MHProNews was an MHI member. Checking the MHI email to members dated March 18, 2014, there is no mention whatsoever to been seen about the DOE issue.
  • If this was an effort that MHI was proud of, why was there no “MHI in Action” or “Housing Alert” type of email to members to say how great this idea is for the industry and its consumers?

Restated, if MHI were sincerely working for all in this matter, then why didn’t MHI inform their own members that they claim to be working on behalf of to the DOE?

That noted, the letter signed by then MHI VP Lois Starkey started with this.


quotequotationMark198x330Dear Ms. Hogan:

On behalf of the Manufactured Housing Institute (MHI), the national trade association representing all sectors of the manufactured housing industry, including manufacturers representing almost eighty percent of the production, retailers, suppliers, lenders, and community owners, I am writing to respectfully request that the DOE consider negotiated rulemaking for the establishment of energy efficiency standards for manufactured housing.”


Further into that same MHI letter, “ MHI and its members would be delighted to participate and support such an effort. We have taken the first steps to achieve consensus on new energy standards by participating with other energy stakeholders in the development of joint comments to DOE in response to its June RFI.” As an upcoming report will reveal, those ‘stakeholders’ are arguably opponents of  several aspects of manufactured housing’s HUD standards. Restated, MHI is telling the DOE that they are working with others that make odd bedfellows, IF MHI is authentically working for “all segments” of the industry, as they claim.

What MHARR or any other organization or individual who understood what MHI was proposing – apparently without the knowledge of the broad cross-section of their own membership – is that MHI was pitching working with outside organization that are arguably often the de facto adversary of our industry’s performance based operating principles.

This once secret MHI letter on MHI letterhead requests, among other points, to “establishes a tight meeting schedule with a minimum of meetings.”

  • Restated, MHI wanted to rush this through, apparently without the knowledge of the bulk of its members.
  • Even if the members had been given this document, which there is no known evidence that it did so, it would require a certain level of explanation in order for its true implication to be understood.

But seemingly, MHI did not risk revealing this letter then or since.

  • This letter is not in their March 18, 2o14 email to members.
  • This letter is not on the public side of the MHI website.
  • Thus, the evidence-based case can be made that MHI was attempting to backstab many of its own members, while apparently making deceptive claims to DOE that they were doing so on behalf of those members.

With that backdrop, let’s see how this arguably treacherous document fits into the bigger picture. Let’s quickly note that this claims it was sent by U.S. Mail, and by what federal law describes as a meaning of “the wires,” which brings into focus certain legal concerns on behalf of those involved. See the top of the screen capture of the photo copy which clearly says: Message “Transmitted via email and U.S. Mail” on 3.14.2014. These could trigger RICO, antitrust, and other possible ‘felony’ violations of law.


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How This Smoking Gun Document Fits Into the Bigger Picture

If the basic premise of HUD Code manufactured housing is undermined from without or within, the effect could be the same. But the case has been advanced that for some years, manufactured housing has been fought from its conventional rivals.

  1. That case is made by outside researchers such as James A. “Jim” Schmitz and his colleagues, who have called out HUD, “builders” and the NAHB specifically.
  2. The outsiders looking in case that manufactured housing is being undermined from within, and that MHI is a key part of that effort, has been made by third-party researcher Samuel “Sam” Strommen at Knudson Law. Strommen and Schmitz et al approach the issues from different perspectives, but their research complements each other.
  3. Then there are the revelations from the recent SEC case against Cavco Industries, and former Cavco and MHI chairman Joseph “Joe” Stegmayer.
  4. Additionally, there are voices that MHProNews has gathered for the last several years that have openly and/or anonymously criticized MHI and/or key MHI members.
  5. A four-legged stool is arguably more stable than one with one, two or three legs. But perhaps the most stable stool is a five-legged stool. You can lose one or perhaps even two legs, and still have a stable seat. By analogy, that is what the case against MHI and its dominating brands now appears to have, 5 clearly identifiable legs. The fifth leg are documents and claims by MHI and its own members, examined in the light of other known facts. In essence, the historic ‘trends’ or patterns of behavior have been steadily exposed in recent years, culminating in the last year or so by research from Strommen, Schmitz et al, and the SEC pleadings.

MHARR’s comments linked below, and others from time to time, have mentioned a ‘tainted’ process. What does that specifically mean? There are several ways that it could be interpreted. But in the light of this document on MHI letterhead, what is hereby exposed is that MHI has actively sought these standards from DOE.  MHI asked DOE in writing for these costly requirements that MHARR has argued are unnecessary and contrary to the purpose that makes manufactured homes valuable to millions of current and potential consumers.


https://www.manufacturedhomepronews.com/manufactured-housing-institute-mhi-shifts-on-doe-regulatory-rule-report-analysis/ Image credits are as shown, and when provided by third parties, are shown under fair use guidelines. Collage credit, MHProNews.com.


When other examples of apparently flawed advocacy are taken into account, this is yet another example of “MHI in Action” – but that action is routinely upon careful examination evidence of their doing the wrong actions. Four examples of that are linked below.


Bat Guano – “The government wants high quality, low cost housing and manufactured housing provides that product.” – Warren Buffett, per Manufactured Housing Institute; Examining Statements on Manufactured Home Financing








There is another document in hand on this topic as is noted above. That will be examined by MHProNews in the near term.

Meanwhile, compare and contrast what MHI has done, and apparently continues to do, vs. MHARR on this or other issues.  MHARR seems to be the most consistent, transparent, and authentic professional trade group that is working in manufactured housing. Unlike MHI, MHARR posts the bulk of what they do online and also in emails to their members and readers.  There is thus an easy way to see if words and behaviors line up.

One of several takeaways noted now and previously by MHProNews, is that by MHI hiding their own content from their own members after they email, that history can easily be ‘lost.’ Accountability is hampered, and transparency is obviously diminished. Those factors point to collusion within MHI’s leadership that dates back for years. The evidence suggests that it began some time after the dawn of the Berkshire era in manufacture housing, when consolidation became a key motivating factor for industry professionals.



By carefully tracking the various statements and claims, past or present, by Warren Buffett, Kevin Clayton, Clayton Homes, MHI, et al, MHProNews is able to demonstrate the apparent disconnects between their prior claims and their later deeds.
Some people, sadly professionals at times included, will not look carefully at what the data is actually telling them. That’s why MHProNews carefully unpacks revelations, so that those who want to know can see reality vs. the ersatz claims. 


Next up is our business daily recap of yesterday evening’s market report, related left-right headlines, and manufactured housing connected equities.

The Business Daily Manufactured Home Industry Connected Stock Market Updates.  Plus, Market Moving Left (CNN) – Right (Newsmax) Headlines Snapshot. While the layout of this daily business report has been evolving over time, several elements of the basic concepts used previously are still the same. For instance. The headlines that follow below can be reviewed at a glance to save time while providing insights across the left-right media divide. Additionally, those headlines often provide clues as to possible ‘market-moving’ news items.


Market Indicator Closing Summaries – Yahoo Finance Closing Tickers on MHProNews…

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(UT-R) has accused the Biden team of implementing policies that harm the poorest and middle class more while enriching the wealthy. Weeks before others in the mainstream media began to flash their ‘inflation warnings,’ MHProNews added first the top, then later the second notice above. When someone has even a basic understanding of the principles of economics, ‘inflation’ was predictable. The question is, will hyper-inflation follow? There are voices on both sides of that debate.

Headlines from left-of-center CNN Business – from the evening of 10.14.2021

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  • This website helps you imagine what extreme climate change will do to your home
  • It’s both a helicopter and a plane. Joby says this is the future of flying
  • A pedestrian walks on Market Street in San Francisco, California, U.S., on Tuesday, Oct. 5, 2021.
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  • Fortune 500 CEO: ‘Work-life balance is a lie’
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  • See the double elimination on ‘Dancing with the Stars’ Disney week


Headlines from right-of-center Newsmax – evening of 10.14.2021

  • 6 Panel Sets Contempt Vote for Bannon, Drawing Sharp Rebuke by Trump
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  • Rosendale: Supply Chain Shortage Makes US Look Like Russia | video
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  • Alleged Rape Victim’s Family to Pursue Legal Action Against Loudoun County
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  • The House Jan. 6 Committee has set a contempt vote for Steve Bannon [Full Story]
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  • The U.S. Food and Drug Administration (FDA) will send drug maker [Full Story]
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Manufactured Housing Industry Investments Connected Equities Closing Tickers

Some of these firms invest in manufactured housing, or are otherwise connected, but may do other forms of investing or business activities too.

                          • NOTE: The chart below includes the Canadian stock, ECN, which purchased Triad Financial Services, a manufactured home industry lender
                          • NOTE: Drew changed its name and trading symbol at the end of 2016 to Lippert (LCII).
                          • NOTE: Deer Valley was largely taken private, say company insiders in a message to MHProNews on 12.15.2020, but there are still some outstanding shares of  the stock from the days when it was a publicly traded firm.  Thus, there is still periodic activity on DVLY.
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Bat Guano – “The government wants high quality, low cost housing and manufactured housing provides that product.” – Warren Buffett, per Manufactured Housing Institute; Examining Statements on Manufactured Home Financing

As the Summer of 2021 draws to a close

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Enjoy these ‘blast from the past’ comments.

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All on Capitol Hill were welcoming and interested. But Congressman Al Green’s office was tremendous in their hospitality. Our son’s hand is on a package that included a copy of the Constitution of the United States and other goodies. Tamas has grown considerably since this photo was taken. 

By L.A. “Tony” Kovach – for MHProNews.
Tony earned a journalism scholarship along with numerous awards in history. There have been several awards and honors and also recognition 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.


mas kovach mhpronews shopping with soheyla .jp

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