Unpacking PR with Kevin Clayton-‘Clayton Applauds New FHA Appraisal Requirements Improving Valuation of Off-Site Built Homes’ What Manufactured Housing Institute Members May Not Say; plus MHMarket$


Facts-Evidence-Manufactured Home Industry Expert News Analysis. There is no single factor that explains why the manufactured housing industry is underperforming during an affordable housing crisis. There are several factors, which researchers and manufactured housing industry pros alike agree include the challenges of barriers in zoning and inequalities in finance. That noted, this report and analysis will ‘unpack’ or critically and analytically examine what part, if any, has been played by the CrossMod® Homes in the contemporary underperformance of manufactured housing during an affordable housing crisis.

As part of the context for this analytical journalistic article, the press release (PR) published by Clayton Homes 12.14.2023 is provided below in Part I. That Clayton Homes press release included a version of a video apparently produced by ManufacturedHomes.com for Clayton Homes. Both Clayton Homes and ManufacturedHomes.com are ‘award winning’ Manufactured Housing Institute (MHI) members.

Part II of this report with analysis is the transcript of that Kevin Clayton-Clayton Homes-ManufacturedHomes.com video. That transcript was generated by YouTube as shown on 12.15.2023 of the video, which is also provided in Part II.  The YouTube version of that video features the voice and image of Kevin Clayton, President and CEO of Warren Buffett led Berkshire Hathaway (BRK) owned Clayton Homes.  That slick-looking 2:28 second video is also provided below.

Part III is a recent HUD News release. It was referenced by Clayton Homes press release, so it helps round out a complete picture of what Clayton Homes and others at MHI are putting forth in their ongoing pitch regarding CrossMods.

Part IV will be still more related information, including sources and insights not previously raised in the ongoing fact-checks and analysis by MHProNews/MHLivingNews with regards to the apparently low-low production performance of CrossMods. How CrossMods has impacted the overall production of manufactured housing will be considered in the light of trends in manufactured housing in the late 20th and the 21st century. In short, there will be an array of facts and evidence provided.

As part of the preface for this article, it is useful to understand what analytical journalism is.

According to left-leaning Wikipedia: “Analytic journalism is a field of journalism that seeks to make sense of complex reality in order to create public understanding. It combines aspects of investigative journalism and explanatory reporting.”

Academic-Accelerator.com similarly stated: “Analytical journalism is the branch of journalism that seeks to understand complex realities in order to generate public understanding.” (Bold emphasis apparently generated by Google in the search used for these definitions). That source also stated: “The main purpose of analytical journalism is to explain. Provide context for your subject matter by providing background, historical details, and statistical data. The goal is a comprehensive description that shapes the viewer’s perception of the phenomenon. Analytical journalism seeks to collect disparate data and establish connections that are not immediately apparent.”

As noted, Part IV of this analytical journalistic report will be additional information that are not part of the press release or video provided by Clayton Homes nor from HUD’s release, but both of those will be explored. As a factual teaser, Part IV includes insights and information generated by MHI which are NOT provided by Clayton or ManufacturedHomes.com as further context for examining the 12.14.2023 Clayton Homes PR. Part IV will also include information from Equity LifeStyle Properties (ELS) owned MHVillage’s MHInsider. According to MHVillage, they are “endorsed” by MHI. The MHInsider trade publication has featured several MHI member firms. MHInsider has also featured the writing of MHI CEO Lesli Gooch. As a disclosure, none of this should be considered an endorsement of Kevin Clayton, Clayton Homes, Berkshire Hathaway, MHI, ManufacturedHomes.com, ELS, MHVillage, or MHInsider. ManufacturedHomes.com will also be explored in this context, as closing credits for the Clayton video reflects that they produced the video used in the Clayton release which was posted on YouTube.

As this is an analytical journalistic article, none of those named above should be construed are being endorsement in any sense as a result of this MHProNews report.


Stockholders and Investors – Take Note

Furthermore, because other MHI members beyond Clayton, ELS, MHVillage, and Manufactured Homes have been involved in the CrossMods adventure, this report may prove to be relevant to the shareholders of several publicly traded firms. The question should be asked and answered: do MHI member firms which are publicly traded and involved in this CrossMods venture which have not completely disclosed the kind of information found herein constitute a material breach of their duties to investors?

To shed further light on the CrossMods subject, insights from the Modular Home Builders Association’s (MHBA) Tom Hardiman, and the Manufactured Housing Association for Regulatory Reform (MHARR) is also included, along with fresh insights from other sources as shown herein in Part IV.

It should be noted that investors are not the only ones potentially harmed by CrossMods. There is an evidence-based case to be made that the employees of manufactured housing industry firms, as well as smaller businesses may also be harmed.

Tom Hardiman, in comments that will be provided, alleged that CrossMods could hurt the valuation of other manufactured homes that aren’t a CrossMod®.  But the harms go beyond that, according to fresh insights from sources which will be provided.

Indeed, due to the creation of MHI branded and Clayton Homes, Skyline Champion (SKY) and Cavco Industries (CVCO) supported CrossMods, would there be a need for MHARR to refer to all other manufactured homes as “mainstream” manufactured housing?

Finally, Part V of this article is our Daily Business News on MHProNews updates on manufactured housing industry connected equities report. In the light of the information provided, one might ask: how much higher might manufactured home industry connected equities be if CrossMods had never existed and a broader and long-overdue promotion of ALL manufactured homes had occurred instead of investing years of efforts and untold total dollars in trying to get traction for CrossMods, which was pitched early on – and again by Kevin Clayton below – as a way of growing the manufactured housing industry and its housing market share?

With that plan for this facts and evidence-based exploration of “CrossMods,” Kevin Clayton, et al, let’s begin.

Part I

Clayton Applauds New FHA Appraisal Requirements Improving Valuation of Off-Site Built Homes

Clayton’s CrossMod® Homes Offer an Attainable Housing Solution that Provides Long-term Wealth Building Opportunities for Homeowners

MARYVILLE, Tenn., Dec. 14, 2023 /PRNewswire/ — Clayton, a leading national builder of single-family attainable housing, is positioned to help home buyers benefit from new appraisal guidelines recently issued by the Federal Housing Administration (FHA), which vastly improve the valuation criteria for CrossMod® homes. With the FHA’s updated policy, CrossMod homes will now appraise alongside site-built homes and other CrossMod homes, instead of older off-site built homes without CrossMod features, providing homeowners the opportunity to build equity and wealth over time.



Learn more about Clayton CrossMod homes and the features that make them indistinguishable from traditional site-built homes.




CrossMod homes are challenging zoning restrictions and regulatory barriers where off-site built homes have historically been limited.

Experience the full interactive Multichannel News Release here: https://www.multivu.com/players/English/9130255-clayton-fha-appraisal-requirements/

“We join housing leaders across the country in applauding FHA for their new appraisal guidelines that improve the valuation accuracy for CrossMod homes,” said Kevin Clayton, CEO. “These homes will play an essential role in addressing the affordable housing crisis. We continue to leverage the off-site building process and its sustainable construction efficiencies to help increase housing supply in cities, rural areas, and everything in between – ultimately making homeownership more attainable.”

In growing areas across the country, CrossMod homes are challenging zoning restrictions and regulatory barriers where off-site built homes have historically been limited. For example, two CrossMod homes were placed within city limits in Atlanta earlier this year. The city of Atlanta allows off-site built homes that are secured to a permanent foundation – a zoning ordinance ideal for CrossMod that showcases how flexible policies can increase attainable homeownership opportunities in high-growth cities.

Clayton CrossMod homes include features such as a permanent foundation, an elevated roof pitch, garage, covered porch, drywall interiors and energy-efficient features. These features help make them indistinguishable from traditional site-built homes.

“Increasing the supply of affordable homes in this country will require us to use every tool available to us. That includes innovative solutions like manufactured housing,” said HUD Secretary Marcia L. Fudge in a press release issued November 2, 2023 by the Federal Housing Administration. “The critical step we’re taking today ensures HUD is in alignment with our industry partners, and it will make more quality affordable housing available to people across the country.”

CrossMod homes are built to HUD (U.S. Department of Housing and Urban Development) code and blend the advantages of off-site and site-built construction. With CrossMod, developments can be completed at a more efficient pace, allowing for increased affordable home inventory.

All new Clayton CrossMod homes are eBuilt™, which are homes built to the U.S. Department of Energy’s Zero Energy Ready Home™ specifications and are estimated to save homeowners up to 50% on their annual energy costs1, allowing homeowners to save more money over the lifetime of their home.

Clayton’s CrossMod eBuilt homes are built to add a renewable energy system, like solar, which can offset up to 100% of the home’s energy consumption. The homes are also optimized with energy-efficiency features, like a Rheem® hybrid water heater, low-E windows with argon gas, ENERGY STAR® certified appliances, LED lighting throughout, an ecobee® smart thermostat, and additional insulation.

1 energy.gov ZERH guidelines

About Clayton
Founded in 1956, Clayton is committed to opening doors to a better life and building happyness® through homeownership. A Berkshire Hathaway company, Clayton is a leading single-family, values-driven home builder dedicated to attainable housing, sustainable practices, and creating a world-class experience for customers and team members. The company’s portfolio includes a comprehensive range of site-built, off-site, Tiny, CrossMod® and modular housing. In 2022, Clayton built 62,620 homes across the country. For more information, visit claytonhomes.com.

CrossMod is a registered trademark of the Manufactured Housing Institute.
ENERGY STAR® is a registered trademark owned by the U.S. Environmental Protection Agency.

SOURCE Clayton


Part II – Transcript of Kevin Clayton – Clayton Homes – ManufacturedHomes.com Production of Video Above, per YouTube.

MHProNews Notes: in this transcript that follows, one word is struck (crossbow) and the word CrossMod appears after it in brackets. That is an apparent typo in the YouTube generated transcript which we have corrected for the clarity of the reader. Other typos, including, but not limited to the lack of punctuation, are as in the original transcript generated by YouTube. That noted, “412” below should be 4/12, a reference to the degree of roof pitch.





as we look back at manufactured housing


historically it’s been nine to ten


percent of single-family housing in


America it’s an important 10 percent but


the question became why can’t


manufactured housing be a higher


percentage and so the industry embarked


on study and if they found that if


you’ll add the Aesthetics roof pitch


permanent foundation covered porch a


garage or a carport people would


consider a manufactured home as a viable


housing Choice the number jumps from 10


percent when surveyed to 46 percent


so cross mod home means that it has to


have steeper pitch roof 412 minimum


covered porch carport or garage area


it’s going to have permanent foundation


around the home and Landscaping full


drywall and so with those qualities


which are not that difficult to


accomplish then it gets labeled as a


cross mod home appraisers are looking


for that so when they see that it’s in a


crossbow [i.e.: CrossMod] they know that they’ve either


got to appraise against other cross mods


or find site built and that’s really


what helps


cross mod will play an important role in


helping us overcome some hurdles and


challenges that our industry has


historically faced and those would be


getting parity on the zoning lending and


Appraisal aspects and in many townships


including my hometown once they saw a


cross mod they immediately said we want


these zoned into our area and that’s can


really now happen across the country you


know these are built the same building


materials as a site-built home we’ve got


the same aesthetic features of the site


built home I’m really happy and


everybody in this industry can do their


part at promoting the cross mod to their


local officials the consumers will


dramatically benefit from a cross-mod


home achieving more for their money







Part III – HUD Press Release Referenced and Linked by Clayton Homes’s PR Above, Reproduced Below for Ease of Reading and Enhanced Clarity of the Issues Explored Herein


HUD No. 23-251
HUD Public Affairs
(202) 708-0685
November 2, 2023

Federal Housing Administration Changes Appraisal Requirements for Certain Manufactured Homes to Enhance Financing Flexibility for Borrowers

Updated requirements for valuation of manufactured homes contribute to FHA’s efforts to increase the availability and affordability of manufactured housing as part of the Biden-Harris Administration’s Housing Supply Action Plan.

WASHINGTON – The Federal Housing Administration (FHA) today announced the publication of updated appraisal requirements for the valuation of manufactured homes certified under Fannie Mae’s MH AdvantageTM and Freddie Mac’s CHOICEHome® programs. Federal Housing Commissioner Julia Gordon made the announcement this morning at the Manufactured Housing Institute’s National Communities Conference Fall Leadership Forum in Chicago, IL.

The updates align FHA appraisal requirements with those of other industry participants and will improve the valuation of these homes for borrowers seeking FHA-insured mortgages. These changes also contribute to FHA’s efforts to increase the availability and affordability of manufactured housing as part of the Biden-Harris Administration’s Housing Supply Action Plan.

“Increasing the supply of affordable homes in this country will require us to use every tool available to us. That includes innovative solutions like manufactured housing,” said HUD Secretary Marcia L. Fudge. “The critical step we’re taking today ensures HUD is in alignment with our industry partners, and it will make more quality affordable housing available to people across the country.”

“Updating FHA appraisal requirements to align with the Fannie Mae and Freddie Mac certification programs supports our comprehensive efforts to increase both the supply and affordability of manufactured homes,” said Federal Housing Commissioner Julia R. Gordon. “Today, we’ve removed another roadblock limiting the effectiveness of FHA programs in serving buyers of these manufactured homes. We hope it will facilitate the continued growth and adoption of this important source of affordable and energy-efficient housing.”

Effective immediately, FHA’s updated policy for the valuation of manufactured homes certified under the Fannie Mae and Freddie Mac programs requires appraisers to use the most appropriate site-built-home comparable sales when there are less than two comparable sales of these certified manufactured homes available. Manufactured homes certified under the Fannie Mae and Freddie Mac programs, also known as CrossMods, include design features that make them nearly indistinguishable from many site-built homes and address regulatory barriers in effect in some jurisdictions that have historically restricted the placement of manufactured homes.


HUD’s mission is to create strong, sustainable, inclusive communities and quality affordable homes for all.
More information about HUD and its programs is available at www.hud.gov and https://espanol.hud.gov.


Part IV – Additional Information with More MHProNews Analysis and Commentary

1) From the HUD-FHA Document cited above by HUD and which is linked above and a HUD-generated PDF copy of it is preserved here on MHProNews, are the following quoted items. The paragraph format and yellow highlighting below mimics the highlighting in the attached HUD/FHA document.


Sales Comparison Approach for Manufactured Housing (II.D.5.k)
i. Required Analysis and Reporting

The Appraiser must include a sufficient number of sales to produce a credible
value. The Appraiser must include at least two Manufactured Homes in the
Sales Comparison Approach (SCA) Grid.

ii. Exception
For a Manufactured Home certified based on the construction requirements of
Fannie Mae’s MH Advantage® or Freddie Mac’s CHOICEHome® program,
the Appraiser must include at least two comparable sales with similar
certification, when available. If fewer than two comparable MH Advantage®
or CHOICEHome® sales are available, the Appraiser must use the most
appropriate site-built comparable sales available and must provide detailed
justification to support the Appraiser’s selection of comparable Properties and
the adjustments made for dissimilarities to the subject Property.
A Manufactured Home certified based on the construction requirements of
Fannie Mae’s MH Advantage® or Freddie Mac’s CHOICEHome® programs
must have Fannie Mae’s MH Advantage® Sticker or Freddie Mac’s
CHOICEHome® Label affixed near the HUD data plate. The Appraiser must
include photos of the Fannie Mae’s MH Advantage® Manufacturer Sticker or
Freddie Mac’s CHOICEHome® Label in the appraisal report for the
Manufactured Home to meet the documentation requirement.



MHProNews will return to the above deeper into this analysis.

2) From the YouTube page that the video in Part I was posted from were these remarks. The views data is as shown on 12.15.2023 at 2:32 AM ET, but for clarity and accuracy, it should be noted that the YouTube video page was opened earlier, sometime after 1 AM ET.

Clayton CEO Kevin Clayton sits down to give an overview of the homeowner benefits, construction process and unique features of a CrossMod® home. These homes blend off-site construction and site-built features to produce a more affordable, innovative home. CrossMod homes can be financed on-par with site-built homes and appraised using similar comps, while drastically increasing the inventory of attainable housing due to the efficiency of the home building process. Find out more about the exciting future of CrossMod and the potential to open doors for more families to achieve homeownership: https://bit.ly/3ReG0sh

Among the remarks posted in the comments on the video are the following.

Great looking homes. They are very professional looking, Mr Clayton.

It is worth mentioning that there are several veterans in manufactured housing, including Marine veterans. One might wonder what ties, if any, this purported veteran might have with manufactured housing? According to YouTube: Channel details

459 subscribers
Joined Jun 27, 2013

Another comment was posted by this writer for MHLivingNews/MHProNews.

As an appropriate online search of CrossMods ®may reveal, the Manufactured Housing Institute (MHI) – which Kevin Clayton led Clayton Homes is an influential part of – apparently contradicts some of the claims made by Kevin in this video. CrossMods ® have had tepid sales from the outset, as data from the FHFA, Fannie Mae, Freddie Mac also seems to reflect. Someone can do much the same with a residential style manufactured home for significantly less money than a CrossMod (R). MHI says appraisals on CrossMods ® have been problematic. By comparison, many more appraisers will have no problem giving a reasonable appraisal on a new manufactured home. There are several factual and common sense reasons to believe that the agenda for CrossMods is ® not what it may appear to be at first blush, if someone takes Clayton at face value.”
3) The following inquiry was put to Bing AI on 12.15.2023 at about 2:46 AM ET.  Bing AI, sometimes referred to as Bing CoPilot, responded as is shown below.

> “Clayton Homes has issued a press release about CrossMods linked here: https://www.multivu.com/players/English/9130255-clayton-fha-appraisal-requirements/ is it accurate to say that there are no known total figures given by Clayton Homes, the Manufactured Housing Institute, other Manufactured Housing Institute members for the total numbers of CrossMod homes sold since the program was launched? Wasn’t the prior name to CrossMods used by the Manufactured Housing Institute “a new class of manufactured homes?” What facts, data, and other insights can you provide on this CrossMods subject?”



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