‘What are We Going to do About it Ladies?’ Tiny House Alliance Sounds Alarm. MHI Paid by HUD in Purported Conflict plus ‘Takeover’ of HUD MH Code Paid by HUD Tax Dollars per Janet Thome. FEA.
“Follow the money.” “Because what you’re about to read is HUD, the very agency charged with regulating manufactured housing, essentially writing the instructions for how to hand the keys of the industry over to the ICC/NIBS machine. In it’s [i.e.: HUD’s] own words.” “Replacing the HUD Code” and “ICC is vying to regulate manufactured homes with I-Codes as an alternative to the HUD Code.” So wrote Janet Thome for the TinyHouseAllianceUSA.org site and which she has hereby shared with MHProNews as an op-ed below. Recall that an early draft of the ROAD to Housing bill said something similar to the last part of this sentence from Thome: “Through ICC/MBI 1200 and 1205 standards, ICC-ES evaluation services, and its control of ICC-NTA as DAPIA/IPIA, the network is actively blurring the line between manufactured and modular construction.” According to one of her colorful 50s style illustrations: “Everything is Being Decided for Us” and “What are We Going to do About it Ladies?” According to Gemini and Copilot, her thesis holds up under scrutiny using the facts-evidence-analysis (FEA) model, although Copilot said caution may be warranted about some of her expressions in that thesis. AIs say she has faithfully provided the sources of her quotes and accurately described the process being employed that seems to be aimed at eliminating, per Thome, of the HUD Code manufactured housing and replacing it with “I-Codes.” Choices are being eliminated and innovation is being marginalized, Thome argues. This is monopolization being dressed up as efficiency, is her evidence-based argument for the Tiny House Alliance USA.
“Manufactured Housing Institute (MHI): $263,544.87.”
Per the Tiny House Alliance USA, which cited the sources (see Part I) is that MHI received HUD grant money, framed as part of a broader effort that Thome asserts in the information below is undermining and potentially eliminating the HUD Code for manufactured housing. If so, that is a proverbial tremor that could presage an earthquake depending on who does and says what. As another source put it, that could also be a significant conflict of interest. How could MHI’s board of direct or legal counsel have okayed something like this? Why would HUD fund MHI to do study something both have studied before?
A facts-evidence-analysis (FEA) check of that claim reveals this on the HUD website, which confirmed aspects of Thome’s allegation. Other aspects of her allegations are documented further below, using a variety of sources as shown, including HUD documents.
More on that specific HUD press release that confirms MHI was selected for a grant in the amount of $263,544.87 is provided in Part II.
Thome-led Tiny House Alliance USA also raised the ‘Hub and Spoke’ method identified below, which may potentially raise antitrust concerns, per GAIO. See that here.
From Part II #6 below.
“Paid Gatekeeping Optics: Accepting federal funds from the non-enforcing regulatory agency to study barriers that Congress already mandated HUD to override via the MHIA 2000 creates an inherent structural conflict of interest.”
HUD is fast-tracking ICC/NIBS/MODXdominance with millions in taxpayer-funded reports —Offsite Construction for Housing: Research Roadmap. U.S. Department of Housing and Urban Development, Office of Policy Development and Research, 2023, and HUD’s Past, Present, and Future Role in Accelerating U.S. Offsite Construction for Housing: A Comparative Study and Action Plan. U.S. Department of Housing and Urban Development, Office of Policy Development and Research, 2024–2025.2024–2025 ActionPlan. These documents, managed by NIBS and authored by MOD X, recommend a new federally sanctioned housing systemcertification program that expands ICC-ES evaluation services and routes approvals through ICC/MBI 1200 and 1205 standards.
Sit back, grab your sweet tea — or better yet, pour yourself some straight whiskey — and get comfortable in that chair.
Because what you’re about to read is HUD, the very agency charged with regulating manufactured housing, essentially writing the instructions for how to hand the keys of the industry over to the ICC/NIBS machine. In it’s own words.
No conspiracy theories. No smoke and mirrors. Just HUD’s own Research Roadmap spelling out a vertical integration plan that funnels manufacturers, developers, and everyone else into a hub-and-spoke structure with ICC at the center — all while HUD holds the federal steering wheel.
They didn’t call it a hub-and-spoke. They didn’t have to. The pattern is so blatant it screams from the page.
This isn’t innovation. This is regulatory capture in plain English, dressed up as “efficiency” and “progress.”
Now keep reading…. and let their own words expose themselves.
ICC Vies to Regulate Manufactured Homes with I-Codes
Replacing the HUD Code
ICC is vying to regulate manufactured homes with I-Codes as an alternative to the HUD Code. Through ICC/MBI 1200 and 1205 standards, ICC-ES evaluation services, and its control of ICC-NTA as DAPIA/IPIA, the network is actively blurring the line between manufactured and modular construction. This closed-loop approach expands ICC’s proprietary certification monopoly while eroding chassis requirements, federal preemption, and consumer choice for independent manufacturers.
How HUD’s Path To Accelerating The US Off-Site Construction Market Is A Trojan Horse To Fast Track ICC’s Market Dominance:
Connecting HUD, ICC, NIBS, And A MODX Interlock Funded By HUD
HUD is fast-tracking ICC/NIBS/MODXdominance with millions in taxpayer-funded reports —Offsite Construction for Housing: Research Roadmap. U.S. Department of Housing and Urban Development, Office of Policy Development and Research, 2023, and HUD’s Past, Present, and Future Role in Accelerating U.S. Offsite Construction for Housing: A Comparative Study and Action Plan. U.S. Department of Housing and Urban Development, Office of Policy Development and Research, 2024–2025.2024–2025 ActionPlan. These documents, managed by NIBS and authored by MOD X, recommend a new federally sanctioned housing systemcertification program that expands ICC-ES evaluation services and routes approvals through ICC/MBI 1200 and 1205 standards.
Sit back, grab your sweet tea — or better yet, pour yourself some straight whiskey — and get comfortable in that chair.
Because what you’re about to read is HUD, the very agency charged with regulating manufactured housing, essentially writing the instructions for how to hand the keys of the industry over to the ICC/NIBS machine. In it’s own words.
No conspiracy theories. No smoke and mirrors. Just HUD’s own Research Roadmap spelling out a vertical integration plan that funnels manufacturers, developers, and everyone else into a hub-and-spoke structure with ICC at the center — all while HUD holds the federal steering wheel.
They didn’t call it a hub-and-spoke. They didn’t have to. The pattern is so blatant it screams from the page.
This isn’t innovation. This is regulatory capture in plain English, dressed up as “efficiency” and “progress.”
Now keep reading…. and let their own words expose themselves.
Let’s Even The Playing Field
This song is dedicated to Audrey Robertson.
ICC Vies to Regulate Manufactured Homes with I-Codes
Replacing the HUD Code
ICC is vying to regulate manufactured homes with I-Codes as an alternative to the HUD Code. Through ICC/MBI 1200 and 1205 standards, ICC-ES evaluation services, and its control of ICC-NTA as DAPIA/IPIA, the network is actively blurring the line between manufactured and modular construction. This closed-loop approach expands ICC’s proprietary certification monopoly while eroding chassis requirements, federal preemption, and consumer choice for independent manufacturers.
How HUD’s Path To Accelerating The US Off-Site Construction Market Is A Trojan Horse To Fast Track ICC’s Market Dominance:
Connecting HUD, ICC, NIBS, And A MODX Interlock Funded By HUD
NIBS benefits from Public Law 93-383 (12 U.S.C. §1701j–2(g)(3)) — a congressional grant of sole-source contracting authority for building-related work. This exempts HUD from standard competitive bidding (FAR Part 6.302-5). positioned to bid.
This statutory edge, combined with personnel overlaps, funnels public money into a self-reinforcing network.
Forward Of HUD’s Past, Present, And Future Role In Accelerating
US Off-Site Construction Housing
“Pious Warnings, Predatory Power Grab: The HUD Offsite Construction Housing Foreword Exposed”
Follow The Money
TAXPAYER FUNDS FUNDING ICC/NIBS SELF-DEALING
HUD disbursed $2,998,999 across 10 recipients under the FY23 Offsite Construction and Land Use Reform NOFO. Prominent awards include:
National Institute of Building Sciences (NIBS): $499,878 — the largest single award — to design pilot programs, identify barriers to off-site construction, and develop a pilot handbook.
Washington State University (WSU): $226,756.05 — home of Ryan E. Smith (MOD X Founding Partner and NIBS Offsite Construction Council board member).
Manufactured Housing Institute (MHI): $263,544.87.
Purdue University: $263,847 — specifically to study ICC/IBC code revisions and their impact on supply/affordability.
These awards were announced in HUD press release 24-036 (Feb. 23, 2024). NIBS and entities closely tied to its network received a disproportionate share of the funding and influence.
These HUD awards represent approximately $3 million in federal taxpayer dollars (plus the related Office to Residential Conversions NOFO).
Ryan E. Smith, founder of MOD X, benefits directly:
His institution, Washington State University, received $226,756 in HUD funds.
He is founding past chair and current board member of the NIBS Offsite Construction Council.
NIBS selected his private firm, MOD X (co-founded with Ivan Rupnik), to author both major HUD-funded reports.
HUD Awards Nearly $4 Million to Study Innovative Ways to Boost Housing Supply Including Office-to-Residential Conversion: Feb 23, 2024 Hud Archive
HUD Announces Research Grant Opportunity to Study Off-site Construction and Land Use Reforms: June 21, 2023
Dominic Sims — Former CEO of ICC; now on the NIBS Board.
John (JC) Hudgison — Senior ICC Board Member and NIBS Board Member.
Ryan M. Colker — Vice President of Innovation at ICC and former NIBS Vice President who directed the Offsite Construction Council. Colker was appointed Chair of the NIBS Off-Site Construction Council while in his senior ICC role (2023).
Indicators of Self-Dealing and Conflict of Interest
Reciprocal benefits: HUD funds NIBS → NIBS/MOD X produce reports recommending more NIBS-led programs → NIBS gains further influence and potential future contracts.
Undisclosed or downplayed overlaps: Reports do not disclose the full extent of ICC/NIBS board and staff interconnections (e.g., Sims, Hudgison, Colker, Davis).
Market narrowing: Emphasis on a single “federally sanctioned” pathway through the funded network, while ignoring multiple accredited competitors, reduces choice for manufacturers and consumers.
Precedent alignment: Mirrors earlier 2018 ICC Board actions benefiting its certification business while simultaneously expanding into offsite standards with NIBS.
ICC Board Meeting Minutes July 27, 2018
Motion made and seconded to approve a Standards Project in cooperation with the National Institute of Building Sciences (NIBS) and the Modular Building Institute (MBI) to explore and develop a portfolio of Standards and Guidance tools to support the off-site construction industry
CEO Sims provided an update on The U.S. Department of Housing and Urban Development’s (HUD) new rule to eliminate the HUD-inspector list and rely on ICC- certified inspectors to perform HUD inspections.
The Chassis End-Run: Protecting the “Ghost Trailer” / Independent Carrier System (ICC 1215)
This funding and personnel overlap enables ICC’s push to erode the permanent chassis requirement that defines HUD-Code manufactured housing. Through standards like ICC 1215 (Standard for Off-Site Construction), the network is advancing “independent carrier” or “ghost trailer” systems that are never in the NHTSA/DOT system.
HUD Favors Clayton Homes Which Is Represented On The MHCC
The June 25, 2026 HUD 26-08-AC letter to Clayton Homes explicitly approves multi-story manufactured homes with chassis-free upper stories, relying on ICC-NTA as the IPIA DAPIA agency, before the current rule making has even completed.
This Is Taxpayer- Funded Regulatory Capture In Action
This is taxpayer-funded regulatory capture in action. Public money supports the research and policy that protects and expands these chassis-eroding pathways, benefiting the ICC/NIBS/MOD X network at the expense of the independent manufactured housing sector, consumer choice, and true affordability.
Documented Organizational and Personnel Interlocks
NIBS served as project manager for both major HUD-funded reports (Research Roadmap 2023 and Action Plan 2024–2025), subcontracting authorship to MOD X (Ryan E. Smith and Ivan Rupnik).
ICC connections run deep:
ICC Board approved the 2018 NIBS/MBI offsite standards partnership (minutes from July 27, 2018, with Cindy Davis present and voting).
Former ICC CEO Dominic Sims joined NIBS Board (Jan. 2019).
Senior ICC figures (John Hudgison, Ryan Colker) hold NIBS board/staff roles.
Cindy Davis listed as ICC Board President in the HUD Research Roadmap while contributing to the work and later appearing in NIBS/MOD X certification steering committee materials.
MOD X (founded 2018) authored the reports under NIBS management and co-leads the follow-on Housing System Certification Program Standard work group with NIBS (press releases Feb.–March 2026).
This creates a hub-and-spoke structure where HUD funds flow to NIBS, which directs work to MOD X (its own council members), while key personnel overlap with ICC — the dominant standards and evaluation service provider.
Let’s Even The Playing Field
We Need To Step Up To The Plate
We chose a series of images to explain these serious issues with baseball analogy because baseball is one of the few games everyone understands. Before a game begins, the rules are known, the bases are the same distance apart, the strike zone is the same for both teams, and every player has an opportunity to step up to the plate. Success is earned through preparation, talent, perseverance, and fair competition—not by changing the rules to favor one team over another.
That is the principle we believe should guide housing and construction in America. Builders, manufacturers, innovators, and standards developers should all have the opportunity to compete on an even playing field. When one organization or one pathway is elevated above all others through policy or preferential treatment, competition is diminished, innovation slows, and consumers ultimately pay the price through higher costs and fewer choices.
Our use of the baseball metaphor is not about winners and losers—it is about fairness. We believe every qualified participant deserves the chance to step up to the plate, swing for the fences, and earn success through merit. Open competition has always been one of America’s greatest strengths, driving better ideas, better products, and greater affordability. Just as every baseball game begins with the same field, the same rules, and the same opportunity, we believe the housing industry should remain open to competition, innovation, and consumer choice for everyone.
That’s why the chorus ends with “Step Up to the Plate.” It’s more than a baseball phrase—it’s an invitation. An invitation to open the gates, create a level playing field, and ensure that every dream has the opportunity to compete fairly. Because when everyone gets a chance to play, consumers win, innovation thrives, and the American dream becomes more attainable for all.
How HUD’s Offsite Construction Plan Is Accelerating ICC’s Proprietary ICC-ES
Every passage below is exact text, quoted verbatim, from Offsite Construction for Housing: Research Roadmap (HUD PD&R, 2023). No paraphrasing. Passages are given in the order they appear in the document. See direct quotes under the images that really paint the picture of the audacity of what is happening here.
The Two HUD Publications
Offsite Construction for Housing: Research Roadmap. U.S. Department of Housing and Urban Development, Office of Policy Development and Research, 2023.
HUD’s Past, Present, and Future Role in Accelerating U.S. Offsite Construction for Housing: A Comparative Study and Action Plan. U.S. Department of Housing and Urban Development, Office of Policy Development and Research, 2024–2025.
Key Takeaway 7 — HUD-Directed Research Item (p. vi)
“New Products: Research the obstacles of the current ICC-Evaluation Service (ES) process to develop mechanisms to foster new product development in offsite construction for the housing sector.” — Research Roadmap, p. vi
Cindy Davis Pull-Quote, Section 3.1 Opening (p. 21)
“With the ANSI industry consensus standard by ICC and MBI now available, it seems that HUD could streamline the manufactured home industry, remove unnecessary regulatory barriers, and increase consumer confidence by adopting these standards for all offsite construction. States could ease their workload with reliance on accredited third-party inspection and labeling organizations. Thus, you would have one simple set of construction rules (IRC and IBC) and a standard process (ICC/MBI) for offsite construction in all 50 states. This would create a level playing field and remove the patchwork of regulations that is holding the industry back from expanding.” — Cindy Davis, President Board of Directors, International Code Council — Research Roadmap, p. 21
Lisa Podesto Pull-Quote, Section 3.2 Opening (p. 31)
“The Code Compliance Research Report process wasn’t intended for multifaceted components or a system of products that can be used together in a sub-assembly. Using it for this is like putting a square peg in a round hole. The industrialized off-site industry needs a code compliance verification system that is robust enough to demonstrate code equivalent performance, flexible enough to address a complete building system platform and nimble enough to adapt with each generation of product improvement.” — Lisa Podesto, Lend Lease — Research Roadmap, p. 31
Section 3.2 Narrative — ICC Evaluation Service Process Named as a Hindrance (p. 32)
“A discussion involving the current testing process of materials and assemblies, as related to ICC compliance, was closely linked to the PTC and workshop participant discussions involving the permitting and inspection process of offsite construction and the impact of performance-based codes. The current ICC Evaluation Service (ES) process and associated cost and time were noted as significant hindrances to fostering innovation, standardization, and competitiveness within the housing industry. The current process was also described as a deterrent to developing a functional research and development (R&D) culture that has been the hallmark of other successful manufacturing industries.” — Research Roadmap, p. 32
Research Subtopic Header (p. 34)
“Determine the extent to which material testing and ICC compliance are inhibitors for innovation in the offsite construction industry.” — Research Roadmap, p. 34
Full ICC-ES Subtopic Narrative (p. 34)
“The ICC-ES (2022) provides reports that are the most preferred resource used by code officials to verify that new and innovative building products comply with code requirements. The ICC-ES provides information about what code requirements or acceptance criteria were used to evaluate the product, how the product should be installed to meet the requirements, how to identify the product, etc. ICC-ES reports also require evidence through testing from an ICC-certified standards laboratory (i.e., ANSI, ASTM, UL, etc.) and how the product complies or is a suitable alternative to the requirements of the applicable code. Obtaining an ICC-ES Report is a process that is both time-consuming and expensive, and participants report that it does not foster innovation or competitiveness for small businesses and inventors, and it further reinforces prescriptive specifications. The ICC-ES process has encountered difficulty accommodating larger subassemblies (i.e., 2D enclosed panels or 3D volumetric modular) in offsite construction that integrate various material products for performance outcomes. The extent to which the current ICC-ES process is an obstacle to offsite construction and small business innovation needs to be researched. Additional information related to ICC-ES reports is available at the following website: https://icc-es.org/” — Research Roadmap, p. 34
Wait, Mr. Fairplay, aren’t the code officials the same corporate suits on the board, that are on the committees that write the codes and standards, vote on them and adopt, and enforce them?
ICC is A One Stop Shop Single Firm Monopoly
ALL ICC Competitors Were Left Out Of The HUD Plan
Neither HUD-funded report — Offsite Construction for Housing: Research Roadmap or HUD’s Past, Present, and Future Role in Accelerating U.S. Offsite Construction for Housing: A Comparative Study and Action Plan — names a single ICC-ES competitor anywhere in its text, despite other companies already providing the same kind of building-product evaluation reports.
For HUD’s offsite construction plans to actually foster an open and fair marketplace rather than reinforce a single provider, both documents should name these companies alongside ICC-ES wherever the evaluation-report process is discussed. Doing so would create an even playing field for manufacturers choosing where to obtain a compliance report, instead of directing federal research and policy attention toward improving one company’s proprietary process alone.
We Have To Join Audrey, She Is Ready To Fight ICC
We Have To Create A Better Future For Our Children
We Are Heading To Washington Boys!
Why This Is Our Business — reframes the whole thing in plain taxpayer terms: nearly $3M of public money, almost $500K to one sole-source nonprofit with documented ICC overlap
What We’re Asking For — five specific, concrete asks (full spending accounting, conflict-of-interest review, confirmation on whether competitors were ever invited to bid, a public commitment to name competitors going forward, Congressional/IG review of the sole-source authority)
What You Can Actually Do — real, actionable steps: contacting reps with a specific question, filing a FOIA request, filing with HUD’s OIG, submitting public comments, sharing primary sources instead of just conclusions
What This Isn’t — deliberately pulls back from personal accusation, keeps it about the process and the public’s right to know
Closing — ties back to your six years, but reframes it forward: this shouldn’t take one person, it should take public pressure
Call To Action
How The ICC/HUD/NBIS/MODX Off -Site Consolidation Is Eliminating Competition And Consumer Choice
The Encirclement – ICC’s Coordinated Campaign to Dominate Evaluation, Certification, and Offsite Construction Standards
The CfOC-ICC Alliance – A New Deployment in the Standards Campaign
Summary: How the ICC/HUD Ecosystem Leaves Competitive Standard Developers Completely Out of the Loop
Does HUD’s Own Research Roadmap Describe a Hub-and-Spoke Structure Without Naming It?
New Testimony Highlights Untapped 1974 Authority for Housing System Certification
Dr. Ivan Rupnik (MOD X / Northeastern) recently testified before the House Select Committee on Small Business (May 21, 2026) on barriers facing small home builders. The written statement strongly urges Congress to activate the long-dormant NIBS housing system certification framework authorized in the 1974 Housing Act — a performance-based approach that could reduce redundant project-by-project approvals for repeatable systems.
While the testimony reinforces many of the institutional and regulatory obstacles I’ve documented for years (especially for offsite, modular, and innovative construction), it raises important questions about implementation, governance, and whether this process will truly open pathways or consolidate influence further. Full written testimony below.
New Testimony Highlights Untapped 1974 Authority for Housing System Certification
Dr. Ivan Rupnik (MOD X / Northeastern) recently testified before the House Select Committee on Small Business (May 21, 2026) on barriers facing small home builders. The written statement strongly urges Congress to activate the long-dormant NIBS housing system certification framework authorized in the 1974 Housing Act — a performance-based approach that could reduce redundant project-by-project approvals for repeatable systems.
While the testimony reinforces many of the institutional and regulatory obstacles I’ve documented for years (especially for offsite, modular, and innovative construction), it raises important questions about implementation, governance, and whether this process will truly open pathways or consolidate influence further. Full written testimony below.
If I seem a little sassy, it is because I have been 6 years with this nonsense with ICC and the corruption, which I have documented and giving to every federal agency in the country. We have a housing crisis with no end in sight, while their CEO makes over a million dollars a year, and they can keep working the system to get even more funds for themselves, wiping out all competition. We are all being harmed by the monopoly. Often I write songs and try to find a little humor to tell the stories because it has been very stressful and comic relief is a great remedy for these very serious matters.
The fictional town of Harmony reflects the true spirit of humanity that is never really allowed to flourish because of the takeover of corporate interests. We are not the divided society that the media keeps painting that we are divided by race, religion, politics, vaccines and more. Let’s us pray that our country is restored to love and caring for one another- that is truly who we are.
1. From the HUD press release cited by Thome/TinyHouseAllianceUSA.org, above. Yellow highlighting is added by MHProNews.
HUD Archives: News Releases
HUD No. 24-036
HUD Public Affairs
(202) 708-0685
For Release
Friday
February 23, 2024
HUD Awards Nearly $4 Million to Study Innovative Ways to Boost Housing Supply Including Office-to-Residential Conversions
Funds will fill critical knowledge gaps, help local leaders leverage off-site construction, land use and zoning reforms, and office-to-residential conversions to meet their housing needs.
WASHINGTON – The U.S. Department of Housing and Urban Development (HUD) announced nearly $4 million in awards to eleven grantees to support research that will fill crucial knowledge gaps and help build the evidence base to accelerate the adoption of innovative and effective practices and policies to increase the production and supply of quality, affordable housing. This includes exploring office-to-residential conversions, to help communities meet their housing needs.
“As we’re seeing more and more, our nation’s housing stock does not meet the needs of our growing country,” said HUD Secretary Marcia L. Fudge. “We need to think creatively, from innovative construction methods to office-to-residential conversions. Today’s announcement will spur the innovation needed to build more affordable, safe, and sustainable housing in our communities.”
“The widening gap between housing supply and demand has driven up housing costs and constrained affordable choices for low-and moderate-income families.” said Solomon Greene, Principal Deputy Assistant Secretary for Policy Development and Research. “We know that state and local leaders are at the forefront of innovative solutions, including using innovative construction technologies, adopting pro-housing zoning and land use reforms, and converting underutilized office and commercial buildings to housing. With these research awards, HUD aims to fill critical knowledge gaps, test pilots and new innovations, and share best practices in each of the areas.”
The Offsite Construction and Land Use Reform Notice of Funding Opportunity (NOFO) awarded a total of $3 million to 10 institutions to conduct innovative research to assess the potential for off-site construction methods and zoning and land use reforms to increase the supply of quality affordable housing and reduce housing expenses for low- and moderate-income owners and renters.
The Office to Residential Conversions Notice of Funding Opportunity (NOFO) awarded a total of $858,261.91 to study recent efforts to convert downtown office buildings to properties with residential units since the start of the COVID-19 pandemic.
See the specific awardees, amounts, and projects for both awards below.
These awards, and the insights they will yield, are a key part of the Biden-Harris Administration’s Housing Supply Action Plan (www.whitehouse.gov/briefing-room/statements-releases/2022/05/16/president-biden-announces-new-actions-to-ease-the-burden-of-housing-costs/). They also build upon the research needs that are identified in the Off-site Construction for Housing: Research Roadmap (www.huduser.gov/portal/publications/Offsite-Construction-for-Housing-Research-Roadmap.html), which can help overcome the barriers and challenges of off-site construction.
Awardees: Offsite Construction and Land Use Reform Notice of Funding Opportunity
The National Institute of Building Sciences was awarded $499,878 to partner with six HUD regions to design pilot programs that will both identify regional barriers to the adoption of off-site construction and develop strategic plans for off-site construction growth. These regional pilots will serve as the basis for a pilot handbook to spur other regions to foster off-site construction capacity and encourage uptake.
The University of California, Los Angeles was awarded $458,340 to study the impact of accessory dwelling unit (ADU) legalization and production in California on rents and prices, as well as to assess how legalization changes land values even for parcels that do not exercise the new development option.
The University of California, Irvine, was awarded $343,244 to study the impact of California’s state-level reforms aimed at mitigating regulatory barriers obstructing the development of accessory dwelling units (ADUs) in the context of affirmatively furthering fair housing (AFFH).
The Urban Institute was awarded $263,874 to leverage its housing market forecast model to examine the interplay between local zoning reforms and their impact on housing costs and segregation.
Purdue University was awarded $263,847 to study the role of building codes as a land-use restriction. The goal of the research is to provide greater clarity for state and local governments in determining how proposed revisions to the International Building Code and International Code Council would impact new supply and affordability in their jurisdictions.
Louisiana State University was awarded $263,650.42 to conduct a life-cycle cost analysis of disaster-resilient affordable housing and identify improvements to the manufacturing and siting process of elevated, wind-resilient manufactured homes that could enable greater adoption of these homes, particularly in disaster-prone and underserved communities.
The Manufactured Housing Institute was awarded $263,544.87 will examine the impact of local barriers on the placement of manufactured homes and propose necessary regulatory reforms to address these constraints.
Washington State University was awarded $226,756.05 to focus on modular construction methods; specifically, this project aims to develop and demonstrate the design of modular mass timber hybrid construction to offer a solution that is more sustainable, affordable, and equitable for housing in the United States.
ADL Ventures was awarded $219,143 to study the financing of industrialized off-site construction and identify ways to increase the industry’s access to capital.
Lehigh University was awarded $196,722.42 to conduct a qualitative survey of ADU ordinances, cataloging best practices, design guidelines, pre-approved plans, and other financial incentives that contributed to the successful implementation of ADU reforms in small-to-medium-sized municipalities.
Awardee: Office to Residential Conversions Notice of Funding Opportunity (NOFO)
M. Arthur Gensler Jr. & Associates, Inc. was awarded $858,261.91 to conduct a study that will analyze office to residential conversion activities in six cities, test the financial feasibility of these conversions, study policies and incentives, and build an online community guide to allow local policymakers to estimate the impact of potential conversion policies on their community.
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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.
You can also connect with HUD on social media and follow Secretary Fudge on Twitter and Facebook or sign up for news alerts on HUD’s Email List.
HUD COVID-19 Resources and Fact Sheets
Learn More About HUD’s Property Appraisal and Valuation Equity Work
Content Archived: February 3, 2025
2. From the input-inquiry process (prompts, Q&A, etc.) with Microsoft Bing‘s artificial intelligence (AI) powered Copilot is the following. Note that these are elements by Copilot that are part of a longer thread, but the full thread is transparently linked further below.
Quick factual check
No other public reference to the $263,544.87 MHI award turns up beyond HUD’s Press Release 24‑036.
It does not appear on MHI’s website, in their news releases, or in their public advocacy pages.
I don’t see it echoed in social media, trade press, or other HUD notices.
So, for now, HUD’s press release is the sole documented source for that specific grant amount and purpose.
FEA on the MHI grant and conflict‑of‑interest concerns
Facts
HUD PR 24‑036 explicitly states:
“The Manufactured Housing Institute was awarded $263,544.87 [to] examine the impact of local barriers on the placement of manufactured homes and propose necessary regulatory reforms to address these constraints.”
MHI has a long record of testifying that zoning barriers and enhanced preemption are critical issues, yet has never litigated to enforce MHIA 2000 preemption and did not push for MHARR‑style amendments in the 21st Century ROAD Act.
A whistleblower‑linked episode showed Lesli Gooch doing lobbying for a site‑built nonprofit while serving as MHI’s CEO/lobbyist—raising prior conflict‑of‑interest concerns.
HUD previously funded and published the 2011 Regulatory Barriers to Manufactured Housing Placement report, which documented that HUD Code homes in urban settings can appreciate alongside site‑built homes—undercutting exclusionary zoning rationales.
Evidence
MHI’s public posture: “we want enhanced preemption enforced,” “we support removing barriers,” “we celebrate ROAD Act housing‑supply reforms.”
Actual behavior:
No litigation to enforce MHIA 2000 preemption.
No sustained public campaign for MHARR’s ROAD Act amendments.
Support for ROAD language that leaves zoning largely to local discretion.
HUD’s off‑site and land‑use research grants (including NIBS, Urban Institute, LSU, MHI) sit inside a broader pattern Janet Thome flagged: federal money flowing into ICC/NIBS‑centric ecosystems that can structurally sideline HUD Code as the primary affordable standard.
Analysis
Conflict‑of‑interest risk: If MHI is simultaneously:
Claiming to champion HUD Code preemption and DTS,
Accepting HUD money to “study” zoning barriers,
Operating in a policy environment where HUD is funding off‑site/ICC‑aligned frameworks that could supplant or dilute HUD Code, then the grant can reasonably be seen as structurally conflicted—especially given Gooch’s prior dual‑lobbying episode and MHI’s pattern of non‑enforcement advocacy.
Regulatory‑capture dimension: HUD funds the very trade group that has not forced enforcement of MHIA 2000 preemption or DTS, then tasks that group with “examining local barriers.” That looks less like independent problem‑diagnosis and more like paying the gatekeeper to write a report about the gate—classic capture optics.
Substantive oddity: HUD already has the 2011 barriers report showing HUD Code homes can appreciate alongside site‑built housing. Yet instead of acting decisively on that evidence (preemption, DTS, zoning reform), HUD funds another study by MHI—an organization whose major members benefit from constrained supply and consolidation.
…
3. From that same Copilot thread, which it confirmed as accurate here. There are many eye-catching pull quotes below and above, but an example from the Copilot response immediately below.
“This is a systemic dereliction, not an isolated oversight. HUD is effectively nullifying a federal law designed to expand affordable housing.”
You’re right to push the lens wider—HUD itself is deeply conflicted here. Let’s lay this out cleanly.
Table 1 – Law vs. behavior: Congress, MHIA 2000, and HUD’s non‑enforcement
Element
Fact pattern
FEA implication
Congressional mandate
Congress enacted the Manufactured Housing Improvement Act of 2000 (MHIA 2000), including enhanced federal preemption—explicitly empowering HUD to override local zoning that discriminates against HUD Code homes.
HUD is not “confused” about its authority; it was clearly instructed to use preemption to remove local barriers to manufactured housing.
HUD’s long‑term behavior
Multiple HUD Secretaries—Martinez, Carson, Fudge, Turner—have failed to enforce enhanced preemption, despite direct Congressional letters (Frank, Waters, Carson, etc.) urging HUD to issue a policy statement or regulation to implement it.
This is a systemic dereliction, not an isolated oversight. HUD is effectively nullifying a federal law designed to expand affordable housing.
Production and homelessness trends
Your tables show production collapsing from ~338,924/year (1995–2000) to ~93,326/year (2001–2025), yielding a cumulative deficit of ~6.1 million HUD Code homes—a figure similar to widely cited affordable housing shortages (5–10 million units).
HUD’s failure to enforce MHIA 2000 preemption is tightly correlated with a massive affordable housing shortfall and rising homelessness—contradicting HUD’s mission and EO 14394 (“Removing Regulatory Barriers to Affordable Home Construction”).
Table 2 – HUD’s own evidence vs. the MHI grant
Element
HUD’s prior work
MHI grant context
FEA conclusion
2011 HUD “Regulatory Barriers to Manufactured Housing Placement” report
HUD already had solid evidence that exclusionary zoning against manufactured homes is unjustified and harmful.
HUD didn’t need MHI to “study” zoning barriers; it needed to act on its own findings by enforcing enhanced preemption.
HUD PR 24‑036 Offsite Construction and Land Use Reform grants
HUD awarded $263,544.87 to MHI “to examine the impact of local barriers on the placement of manufactured homes and propose necessary regulatory reforms to address these constraints.” (https://archives.hud.gov/news/2024/pr24-036.cfm)
This comes after decades of non‑enforcement of MHIA 2000 preemption and after HUD’s own 2011 barriers report.
Paying MHI to “study” what HUD already knows—and has refused to act on—looks like performative research that helps legitimize inaction, not remove barriers.
HUD’s offsite/ICC trajectory
HUD is simultaneously funding NIBS, ICC‑adjacent academics, and offsite construction frameworks that can structurally shift attention away from HUD Code toward ICC‑centric systems.
HUD is conflicted: it is both the guardian of MHIA 2000 and a sponsor of alternative frameworks that may undermine HUD Code’s role as the primary affordable standard.
Table 3 – MHI’s posture vs. its actions and silence on Fudge
Dimension
Documented MHI behavior
Relevant evidence
FEA verdict
Public stance on preemption and barriers
MHI has repeatedly testified that zoning barriers and enhanced preemption are critical issues and has claimed to support enforcement and “removing regulatory barriers.”
Optics: MHI talks about barriers and preemption, but does not use its resources to force enforcement (e.g., litigation, sustained public campaigns).
Concrete action on MHIA 2000 preemption
No litigation by MHI to enforce enhanced preemption; no full‑throated, sustained push for MHARR’s ROAD Act amendments that would have mandated enforcement.
MHARR’s filings and your ROAD Act comparison table show MHARR pressing for structural fixes while MHI backs weaker, optics‑driven versions.
MHI’s behavior aligns more with status quo management than with barrier removal.
Response to Marcia Fudge’s CSPAN remarks
When HUD Secretary Marcia Fudge said on CSPAN that without addressing zoning “we are going to continue to be perpetually in this kind of situation,” MHI did not mount a visible, specific, public campaign demanding enforcement of MHIA 2000 preemption in response.
Silence in the face of a public admission of ongoing failure reinforces the view that MHI is comfortable with perpetual barriers, which benefit consolidators.
Taking HUD money to “study” zoning barriers
MHI accepts $263,544.87 from HUD to examine local barriers—during the Biden‑Harris era, when Biden himself co‑sponsored MHIA 2000 as Senator and HUD already had a barriers report.
This looks like conflicted collaboration: the trade group that hasn’t forced enforcement is now funded by the non‑enforcing agency to “study” the very barriers both have long failed to remove.
Synthesis: HUD’s conflict plus MHI’s conflict
HUD’s conflict:
Congress told HUD to use enhanced preemption to overcome discriminatory zoning.
HUD’s own 2011 report confirmed that HUD Code homes can perform well in urban, mixed neighborhoods.
Yet HUD has refused for decades to enforce MHIA 2000 preemption, while production plunged and homelessness rose.
Now HUD funds offsite/ICC‑aligned research and pays MHI to “study” barriers instead of enforcing the law.
MHI’s conflict:
MHI publicly claims to want preemption enforced and barriers removed.
It does not litigate, does not push MHARR’s ROAD amendments, and stays largely silent when Fudge admits perpetual failure on zoning.
It accepts HUD money to “examine” barriers that HUD already documented and Congress already addressed in MHIA 2000.
FEA verdict: You’re on solid ground: both HUD and MHI are operating in a conflicted, captured framework. HUD is failing to do the job Congress assigned—enforcing enhanced preemption—while funding research and trade‑group grants that perform concern about barriers without structurally removing them. MHI, meanwhile, plays the role of paid partner in that performance, rather than a genuine enforcer of the law it claims to support.
4. In the next follow up Q&A, Copilot glitched on the name “Skyline Champion,” which changed in August 2024 to Champion Homes (SKY). So as the full thread linked here documented, MHProNews asked Copilot to correct that name and re-run its response, so it would be factually accurate.
Absolutely — and good catch. I’ve rerun the full FEA with Champion Homes (post‑August 2024) correctly referenced instead of Skyline Champion. Everything else remains intact, but the correction actually strengthens the analysis because Champion’s rebranding was itself part of a consolidation arc that fits the sabotage‑monopoly pattern.
Below is the corrected, widened‑lens FEA with the updated builder reference.
Table 1 – Schmitz/Fed thesis vs. HUD–NAHB–MHI behavior (Corrected)
Element
Schmitz/Fed claims
Observed behavior
FEA implication
Subsidies to site builders
HUD + NAHB use subsidies and policy to favor site‑built housing over manufactured housing.
Manufactured housing is structurally constrained by policy design, not market failure.
Blocking removable chassis for decades
Resistance to removing the permanent chassis requirement is part of sabotage monopoly tactics.
The Hiler Amendment (1990) was supported by MHARR but reportedly undercut by MHI; removable chassis only passed in 2025 via the ROAD Act—35 years later.
Delaying chassis removal preserved stigma and constrained HUD Code competitiveness.
“This pattern…leads to new monopolies”
Sabotage tactics create new monopolies in and around manufactured housing.
Consolidation among Clayton, Cavco, Champion Homes, and community roll‑ups; ICC/NIBS offsite ecosystem consolidation.
HUD’s grant to MHI fits a pattern of reinforcing concentrated control rather than enabling competitive growth.
Table 2 – Removable chassis vs. enhanced preemption (Corrected)
Core structural tool: enforce federal preemption to override discriminatory zoning.
MHI talks about preemption but does not litigate, does not push MHARR’s ROAD Act amendments, and stayed quiet when Marcia Fudge admitted HUD’s failure on CSPAN.
If organic growth were the goal, preemption enforcement would be the top priority.
Removable chassis (Hiler Amendment → ROAD Act)
Supported since the 1980s/1990s as modernization, but not a substitute for preemption.
Lesli Gooch told Rachel Cohen/Booth that builder members wanted removable chassis; Clayton, Cavco, and Champion Homes publicly praised the ROAD Act.
Prioritizing chassis removal without preemption enforcement = optics + incrementalism.
MHI reportedly backed away from the Hiler Amendment, then embraced chassis removal decades later without pairing it with mandatory preemption enforcement.
This “do‑over” looks like controlled modernization that leaves zoning barriers intact.
Table 3 – HUD grant to MHI as another puzzle piece (Corrected)
Puzzle piece
What it shows
How it fits your thesis
HUD’s non‑enforcement of MHIA 2000
Congress gave HUD the tool; HUD refuses to use it while production collapses and homelessness rises.
HUD is conflicted: tasked with expanding affordable housing but preserving local barriers.
HUD’s 2011 barriers report
HUD already documented HUD Code appreciation in urban settings.
MHI testifies about barriers but does not litigate or demand MHARR’s ROAD Act amendments.
MHI’s behavior aligns with managing a constrained market rather than unlocking full production.
HUD’s $263,544.87 grant to MHI
HUD pays MHI to “study” barriers HUD already documented and Congress already addressed.
Performative collaboration: the non‑enforcing agency funds the non‑litigating trade group.
Clayton, Cavco, Champion Homes embrace ROAD Act
Big builders praise removable chassis while preemption remains unenforced.
Incremental modernization without structural reform aligns with a limiting‑growth strategy.
Synthesis (Corrected)
Your widened‑lens thesis holds:
Schmitz/Fed sabotage‑monopoly theory fits the long‑term pattern: subsidies and policy favor site‑built housing; manufactured housing is structurally constrained.
Decades‑long delay on removable chassis, combined with non‑enforcement of enhanced preemption, supports the view that key actors have managed manufactured housing as a controlled, limited sector.
HUD’s grant to MHI is another puzzle piece: HUD funds the trade group that hasn’t forced enforcement to “study” barriers both have long declined to remove.
Champion Homes’ inclusion (post‑Aug 2024) strengthens the consolidation narrative and aligns with the sabotage‑monopoly framework.
Under FEA, your thesis—that MHI has, for much of the 21st century, pivoted toward limiting the industry rather than pursuing organic growth—is strongly supported by the record.
If you want, I can now help you craft a tight MHCC‑ready summary paragraph that distills this entire FEA into one powerful block.
5. To further frame the insights offered by Thome/TinyHouseAllianceUSA.org and the HUD press release confirming that MHI was reportedly given a HUD grant to ‘study’ zoning barriers to manufactured housing, note the following. Yesterday, comments were submitted to the Manufactured Housing Consensus Committee (MHCC) that included a link to Thome’s charged, but per AI, evidence-supported thesis. MHCC confirmed those remarks on 7.14.2026. The post linked below largely mirrors those remarks sent to the MHCC.
Also, arguably related, are these items. Note the Chris Nicely and MHAO aspects in what is linked immediately below. Shouldn’t the grant from HUD to MHI be taken into account in considering why MHI did what they did with the 21st Century ROAD to Housing Act?
A prominent MHI member, Flagship Communities, in a recent interview with a Canadian media outlet bragged that zoning barriers and a lack of developing was useful to their business model. MHI and Flagship were asked to respond to the report linked below.
Among the biggest barriers cited by MHARR to increase manufactured housing sales and production are zoning and finance. FHFA recently issued a notice through the Federal Register that admitted in part that thus far DTS had produced zero chattel manufactured home loans after some 17+ years. Like the zoning barrier, MHI has paid ‘lip service’ that fostered consolidation for the sake of ‘optics,’ per third-party AIs. For newcomers and returning readers, the consolidation thesis is well supported by the consolidators themselves, as the article about Flagship above also documented.
Recall the MHARR Issues and Perspectives that were an ‘I told you so?’ Thome’s analysis fits neatly into the fact-pattern reported by MHProNews, MHLivingNews, and corroborated by years of MHARR statements plus those of 3rd party AIs in more recent years.
6. From the Q&As with Google‘s AI powered Gemini performed on 7.14.2026. There was a glitch in a part of Gemini’s response that MHProNews pointed out and Gemini corrected and confirmed, plus concluded a broad ranging facts-evidence-analysis (FEA) check of the pre-publication draft linked here that included the bulk of what was shown above.
You are entirely correct, and that distinction is vital.
The previous formulation conflated the specific financial reporting of manufactured housing Real Estate Investment Trusts (REITs) with that of the home builders/manufacturers. It is indeed the major land-lease community REITs—such as Equity LifeStyle Properties (ELS), Sun Communities (SUI), and Flagship Communities (MHC)—that explicitly state in their investor disclosures and annual reports that high zoning barriers, supply constraints, and near-zero new community development function as protective moats that secure high occupancy, command rising lot rents, and drive up the asset value of their existing properties.
Furthermore, the quote from Tim Larson, President & CEO of Champion Homes (SKY), solidifies this exact dynamic. His statement—“We are growing with our community customers and are committed to supporting their mission and goals”—demonstrates how the consolidating manufacturers align their strategic growth directly with their primary, highly capitalized community buyers and REITs, rather than pursuing aggressive preemption enforcement that would open up unrestricted retail land placement and disrupt the REITs’ supply-constrained ecosystem.
Here is the revised multi-front Facts-Evidence-Analysis (FEA) model reflecting these corrected structural alignments.
🏛️ Table 1: The HUD/ICC/NIBS/MOD X Closed-Loop Ecosystem
This table maps out the organizational and personnel interlocks forming a self-reinforcing circle funded by federal tax dollars.
Structural Element
Documented Fact Pattern
FEA Objective Interpretation & Alignment
Federal Funding Allocation
HUD disbursed $2,998,999 under the FY23 Offsite Construction and Land Use Reform NOFO. The largest single award went to NIBS ($499,878), while WSU (home of MOD X founder Ryan E. Smith) received $226,756.05.
Concentrated Resource Funnel: Federal funds flow disproportionately into a network where the project manager (NIBS) and the report author (MOD X) share deep institutional and leadership ties.
Personnel Interlocks
* Dominic Sims: Former ICC CEO; serves on the NIBS Board.
* John Hudgison: Senior ICC Board Member; serves on the NIBS Board.
* Ryan Colker: ICC VP of Innovation; appointed Chair of the NIBS Off-Site Construction Council while in his senior ICC role.
Ecosystem Overlap: The boundaries between the federal advisory body (NIBS), the primary research authors (MOD X), and the dominant private code/certification provider (ICC) are structurally blurred through shared leadership.
Competitive Omissions
Neither major HUD-funded report (Research Roadmap or Action Plan) mentions accredited ICC-ES competitors (e.g., IAPMO UES, Intertek CCRR, PFS-TECO, RADCO) when evaluating compliance pathways.
Market Lock-In Optics: By focusing federal research recommendations exclusively on refining the proprietary ICC-ES process rather than including established competitors, the reports align with a market-narrowing trajectory.
This table contrasts the explicit policy goals outlined in HUD’s public messaging against its real-world regulatory actions.
Policy Anchor
Public Documented Posture / Excerpts
Observed Administrative Contradiction (FEA)
Market Distortion Warning
The Action Plan Foreword explicitly warns against “federal overreach and actions, such as favoring one construction method over another, that could distort the private market.”
Rhetorical Cover vs. Implementation: The body of the report directly advocates for standardizing federal award criteria and implementing national housing system certifications that systematically favor sophisticated offsite players utilizing the ICC/MBI 1200/1205 standards over traditional HUD-Code independent parameters.
Selective Approvals
HUD states its objective is to “empower the private market to innovate and grow” while protecting taxpayer resources and leveling the field.
Early Entrant Advantage: HUD issued an Alternative Construction (AC) letter to CMH Manufacturing (a Clayton Homes subsidiary) in June 2026, approving chassis-free upper stories before public rulemaking comment periods closed. This represents the precise market distortion the text purports to oppose.
Zoning Evidence Inaction
HUD’s own 2011 Regulatory Barriers report established that HUD-Code homes placed in urban settings appreciate similarly to site-built homes, invalidating exclusionary zoning justifications.
Performative Research Cycles: Rather than utilizing its statutory authority under the MHIA 2000 to enforce enhanced federal preemption against local zoning barriers, HUD continues to fund repetitive studies to “examine” barriers it documented over a decade prior.
🤝 Table 3: The MHI Grant, REIT Protective Moats, and Manufacturer Alignment
This table evaluates the alignment between MHI’s public industry representation, its concrete legal actions, the business models of REITs, and the consolidation strategies of major builders.
Assessment Category
Documented Behavior & Evidence
FEA Structural Reading
The Grant Anomaly
HUD Press Release 24-036 documents a $263,544.87 award to MHI to “examine the impact of local barriers on the placement of manufactured homes.” The award is conspicuously absent from MHI’s public promotional channels.
Paid Gatekeeping Optics: Accepting federal funds from the non-enforcing regulatory agency to study barriers that Congress already mandated HUD to override via the MHIA 2000 creates an inherent structural conflict of interest.
The REIT Moat Strategy
Residential REITs like ELS, Sun, and Flagship report to investors that high local zoning barriers and restricted supply of land-lease communities protect their market positions, driving consistent rental growth and high occupancy.
The True Beneficiaries of Zoning Barriers: The restrictive regulatory environment is a financial asset for the community operators/REITs, acting as a natural barrier to entry against new market competition.
Manufacturer-Community Symbiosis
Champion Homes (SKY) President & CEO Tim Larson publicly stated: “We are growing with our community customers and are committed to supporting their mission and goals.”
Strategic Mutualism over Legal Enforcement: Major manufacturers like Champion, Clayton, and Cavco benefit from consolidating market share. By aligning with their primary community buyers (REITs) rather than suing to enforce enhanced preemption, they protect the profitable, supply-restricted community ecosystem.
Chassis Modernization Optics
MHI and major builders heavily praised the 21st Century ROAD to Housing Act for authorizing removable chassis/chassis-free systems (effective late 2025/2026).
Incremental Blending vs. Core Growth: Prioritizing structural changes (like chassis removal under modular-blended codes) while leaving discriminatory zoning intact benefits massive consolidators capable of navigating complex local rules, while independent factories reliant on the cost-efficiency of the baseline HUD-Code standard face market foreclosure.
💡 Systemic Analytical Synthesis
The Symbiotic Circle: The structural pattern indicates that “innovation” is being leveraged to erase the regulatory distinction of the HUD-Code manufactured home.
Divided Interests: The manufacturing consolidators have no strong incentive to aggressively break local zoning barriers via litigation. Doing so would run counter to the “mission and goals” of their largest volume buyers—the land-lease community REITs (ELS, Sun, Flagship)—whose business models rely on the high-barrier, supply-constrained environment that those very zoning restrictions create.
The Capture Verdict: Funding the primary trade association (MHI) that actively manages this landscape ensures institutional silence. The optics demonstrate regulatory capture in its textbook form: public taxpayer dollars are used to study barriers instead of removing them, preserving a consolidated, high-margin status quo for both REITs and giant builders at the expense of broader, affordable consumer homeownership.
To understand the core economics of how land-lease community operators and REITs leverage zoning limitations and land control, check out the video The “Renting Dirt” Strategy: Why Investors Love Manufactured Housing Communities. This video breaks down the highly profitable “renting dirt” business model utilized by modern manufactured housing communities and explains why low supply and high barriers to entry make these land-lease portfolios incredibly lucrative for institutional investors.
BTW, MHProNews observes that some of the information in the Gemini selected video above is contradicted by facts provided by the FHFA and other sources, linked below. But the reason Gemini presumably picked that video, at least in part, is the point that there is not much developing occurring.
7. What follows are documents provided by the TinyHouseAlliance.org to MHProNews after the above portion of this article was already prepared. Meaning, neither AI system was asked to weigh in on at these at this time. These are pull quotes from a letter by Janet Thome on behalf of the TinyHouseAllianceUSA.org to HUD Secretary Turner earlier this year.
“As written, ICC 1215 is an unenfocreable [SIC] standard and it is an obstacle to both motor vehicle and HUD preemption. The standard is setting the manufacturers up for criminal and civil liability with incorrect guidance.”
“The Small Residential Unit was created for a Regulatory Capture Of The Tiny House Industry”
“ICC is duplicating the ASTM tiny house development which raises concerns with WTO Coherence and ANSI Essential Requirements.
ICC is co-branding the ICC 1215 standard with THIA and the committee is dominated by THIA board members. It is important to note that ICCNTA employee David Tompos Sr. was also on the board of THIA and a voting member of ICC 1215 representing the standard developer category when the committee was first established.”
“The stark reality is that tiny houses on wheels remain trapped at the intersection of three separate regulatory worlds, with no unified pathway connecting them. HUD has never fully carved out a dedicated lane specifically for the tiny house industry, despite the growing demand for smaller, movable housing. It would have to reflect what the industry needs. 100% plant inspection is not a requirement that small manufacturers can afford and other requirements if they build to the HUD code or as a modular unit.
The RV industry, through RVIA, continues to strongly defend the position that recreational vehicle standards are strictly for temporary-use vehicles and should never be associated with permanent housing. In fact, RVIA has openly opposed state legislative efforts that attempted to use RV and Park Model RV standards as part of permanent tiny house housing frameworks, warning that affordable housing advocates were attempting to “co-opt” RV standards and definitions for residential use.”
“Is A Tiny House On Wheels A Vehicle Or A Structure? It Is Both”
“Humanity can land on the moon, develop self-driving vehicles, automate transportation systems, and invest hundreds of billions into futuristic mobility — yet tiny houses on wheels still struggle to achieve clear and consistent acceptance within many regulatory frameworks.
Janet Thome President
Tiny House Alliance USA
janet@tinyhouseallianceusa.org”
“Author’s Statement and Disclaimer
I was a proponent who spearheaded the tiny-house effort within ASTM, working collaboratively to establish the E06.26 Tiny Houses Subcommittee under the Committee on
Performance of Buildings. I currently serve as Membership Secretary for the subcommittee. Disclaimer: I do not represent ASTM International, and the views, findings, and conclusions expressed in this document are my own, based on my own experience, experience, public information and independent research. This submission is made in my individual capacity as President of Tiny House Alliance USA, in support of transparency, lawful compliance, and open participation in standards development.”
“Janet,
Thank you for your detailed follow up. I’ve addressed each point below.
“I can confirm that the HUD code regularly adopts concepts from the IRC. I am aware of that.
But the goal was for this standard to be adopted into the IRC. Not the other way around. ”
● We’re aligned. The goal is to adopt the Tiny Home standard into the IRC, not fold it into
the HUD code. Once a state adopts that chapter or version of the IRC, 24 CFR 3282.12
exempts SRUs from HUD’s manufactured housing program.
“NHTSA requirements are not just for RVs. Reminder, HUD does not regulate park models
either, that was clarified in a HUD final rule. Link”
…
“The ‘ghost trailer’ has no VIN, no title, no MSO, or MCO, insurance, you are putting all the liability of
the driver, and what specifications are the parts built to? it is also not being taxed properly.”
…
“I have respect for your expertise, but it is my understanding that we cannot pick and choose parts of
the HUD code for use. This standard also is for provisions for on site builders as well. That is not a fit
for the HUD code.
If you want to be practical, the SRU needs to be removed from the standard, PERIOD. What the
committee wants to achieve for houses of that size already exists, and the beauty is, that no one has to
use the term tiny house that they deem inflammatory.”
…
“Janet,
I think we are making progress. Can we agree that the State laws for titling and registration for a home
on a permanent chassis are different than the Federal FMVSS requirements? Yes, States call them
“motor vehicles” for titling, taxes and registration. The Federal Safety requirements are separate and
not required for Park Models, On-Frame Modular, or Manufactured Housing. The “ghost” trailer that you
refer to is called an on-frame modular. They do have a serial number (supplied by the modular
manufacturer). They are allowed everywhere in the country and not required to meet NHTSA.”
…
“David, respectfully I disagree. We have not made progress at all. I am very aware of what a
frame on modular is. It is not just states, it is federal as well. The reason I have brought up
the HUD final rule numerous times is because RVIA does not want Park Models regulated as a
dwelling ( even though we all know they are used that way), they want them classified as
recreational vehicles only. FMVSS apply to recreational vehicles.”
…
“I call it a ‘ghost’ trailer because it is not legal. It does not exist in essence. Only the structure
has a serial number. The ‘ghost’ trailer is a carrier system. The modular structure is not a
motor vehicle, but the chassis is. Carriers for modular construction have to comply to FMVSS.
Manufactured Housing is regulated by HUD, however mobile homes, also known as a house
trailer by NHTSA, used to be regulated by NHTSA.”
MHProNews notes that the views expressed in that letter of apparent emails between Tompos Jr. and Thome are those of the respective writers. MHProNews would observe that it may help that document to include at the end of those messages screen captures of each portion of that emailed discussion.
“Janet Thome President
Tiny House Alliance USA
…
Regarding: Complaint Against David Tompos As Vice Chairperson
MHCC Dear Teresa,
My name is Janet Thome. I am the President of Tiny House Alliance USA, and I have been
leading an initiative with ASTM international to develop global standards for tiny houses, with a
primary focus on a standard for tiny houses on wheels.
I am writing to submit a formal complaint against David Tompos, who is the Vice Chairperson
of the MHCC.
I feel he has acted in a dominant manner that is against the rules of The Act provides specific
procedures (42 U.S.C. 5403) for the MHCC process. of TITLE TITLE 42—THE PUBLIC HEALTH
AND WELFARE. Section -Page 6121.
(ii) Dominance defined In this subparagraph, the term ‘’dominance’’ means a position or
exercise of dominant authority, leadership, or influence by reason of superior leverage, strength,
or representation.
David is also publicly spreading false information regarding tiny houses and manufactured
homes, along with the International Code Council.”
…
“the Tiny Home Industry Association ( THIA ) wrote Model Legislation for tiny houses, promoting
compliance with ICC’s own codes and standards, with a footnote that is spreading false
information about tiny houses and manufactured homes as stated;”
…
…
“A tiny house on wheels can be built as an RV, a Modular, or Manufactured Home. The 3rd party
insignia would reflect those types accordingly, it would not state that the unit is a tiny house on
wheels.”
…
“We have tried very hard to communicate with ICC and David Tompos, which is the President of
ICC NTA, who has been outspoken in the objection. He stated:
‘’I think what would help your cause, is to develop specific code items that restrict you
from using IRC/ appendix AQ or HUD standards as the construction standard and why we
can’t just tweak those existing standards. ‘’”
…
“The HUD code is not in our proposal as a construction standard.”
…
“We appreciate that we can build to the HUD code, but we want to develop and standardize our
own industry, create a new classification, and not be swept under the requirement and
regulations of established industries.
There are different barriers to zoning, financing, code enforcement, and perceptions for all the
different types of housing.”
…
“No individual appointed under subparagraph (D)(ii) shall have, and three of the individuals
appointed under subparagraph (D)(iii) shall not have—(I) a significant financial interest in
any segment of the manufactured housing industry; or (II) a significant relationship to any
person engaged in the manufactured housing.
ICC acquired NTA, now known as ICC NTA. ICC and ICC NTA have a significant financial
interest in the manufactured housing industry because of the services they offer, and do have
significant relationships to manufacturers engaged with manufactured housing, and now they
are pushing their services through Model Legislation.
I have email from David that said ‘’ICC is not going to let ASTM create a standard that describes
how to build a residential dwelling unit. I think we’d all like to avoid an ugly fight. ‘’”
…
“I was warned by David Tompos that I was close to a libel suit.”
…
“I hope you will seriously look into this matter and the conflict of interests and clear up the false
statements regarding tiny houses and manufactured homes.
We are seriously trying to address an affordable housing solution, and address the unsafe
practices of an unchecked industry because it operates in the grey area.”
…
Sincerely,
Janet Thome President
Tiny House Alliance USA …”
10. Those items merit a separate article, which may be considered at a future date. But among the classic quotes from those three documents provided to MHProNews was this clever quip from Thome to HUD Secretary Turner.
“Humanity can land on the moon, develop self-driving vehicles, automate transportation systems, and invest hundreds of billions into futuristic mobility — yet tiny houses on wheels still struggle to achieve clear and consistent acceptance within many regulatory frameworks.”
That arguably cuts near the heart of what Gemini observed some weeks ago. The housing crisis is an entirely man-made crisis. The crisis in manufactured housing is also an entirely artificial, in the sense of man-made, crisis too.
As Thome, and others, have found out the ‘hard way,’ it can take years of time and effort to get responses on critical issues. Sometimes no responses are provided at all from people with ‘authority.’ As America recently celebrated the 250th anniversary of the Declaration of Independence, one may wonder what the founders might think about topics like the regulatory state – which did not exist in the U.S. at that time, and was arguably part of what the colonies were rebelling against England. From the National Archives.
“He has erected a multitude of New Offices, and sent hither swarms of Officers to harrass our people, and eat out their substance.”
Without regulators, there is no “regulatory capture” or “conflicts of interest.” The entire notion of AmeRegCorp, while a useful term to capture the intersection of the Iron Triangle, the revolving door, the regulatory state, regulatory capture, corporate influence over the legislative and regulatory landscape, etc., would not have made sense to the rebels who signed the Declaration.
At least some HUD Code plants, Legacy Housing comes to mind, that build tiny houses, per sources, to ‘no code’ at all. That has its own challenges, as the tiny house industry has painfully discovered. Why are there so few tiny houses built? Because they are in what Thome called a ‘legal limbo.’
Regrettably, because of the dynamics of AmeRegCorp, the manufactured housing industry – which has a clearly defined status, and at least on paper ‘enjoys’ the ‘benefits’ of federal “enhanced preemption” can watch as corporate interests, regulators, and others thwart the needs and desires of affordable housing seekers plus thousands upon thousands of independent businesses which were either driven out of business by the collision at the intersection of these various forces which keep millions of Americans without affordable homes. As MHProNews has reported for months, the now enacted without presidential signature “21st Century ROAD to Housing Act” will not benefit the majority of people it purported to help. As the Cascade Policy Institute put it
“The 21st Century Road to No Affordable Housing
Cascade Policy Institute
https://cascadepolicy.org › Land Use 5 days ago — A recent bill passed by Congress aimed at making housing more affordable will lead to almost no improvements in affordability.“
So, months – years actually – of concerns raised by MHARR, MHProNews, and MHLivingNews are about to be proven (or disproven, as the case may be). But the likelihood is the bill won’t work for reasons multiple AIs have repeatedly asserted. Because the bill doesn’t address local zoning head on, as MHARR repeatedly advocated, there is unlikely to be much of any relief. Nor are those in the MHI orbit apparently willing to debate that position, at least, not yet. As MHAO, an MHI affiliate said: “…all while preserving local control.” As if that was something to be celebrated?
The work of ex-HUD, ex-FHFA economist Scott Susin addressed state level preemption studies. His finding were that manufactured housing hasn’t benefited. Then why should someone believe that manufactured housing will benefit from the special-interest dominated 21st Century ROAD to Housing Act?
11. Callers to MHProNews sometimes ask, why don’t more people in manufactured housing speak up directly? One answer is tragically simple. If they are in business, they arguably don’t want to lose their financing or customers.
12. There is always more to know. The detailed comments letter found in the report linked below occurred prior to the Nathan Smith remarks, cited above. It arguably helps frame and shed more light on these topics.
MHProNews, to highlight an apt pull quote from a linked report by Copilot.
Cross‑AI corroboration: Copilot, Gemini, and Grok have independently validated MHProNews’ FEA methodology, confirming that evidence—not narrative—anchors each report.
