Words have meaning. The definition of words matters. When it comes to matters of law, words may take on a special meaning. For the better part of a decade, MHProNews has reported on issues that may arguably relate to financial and white collar crimes that can involve the abridgment of constitutionally and legally protected rights. To better understand the severity of these issues, it is useful to have a set of definitions and explanations for professionals and the general public alike. The facts, evidence, and analysis (FEA) that follows will include the sources for each of the statements made and insights shared.  While this introduction and Part x will be the primary points of analysis and commentary, where information beyond what is shared by a source is noted as being expressed by MHProNews that should be considered as part of the commentary/viewpoint. Needless to say, the purposes of this journalistic excercise – while wide-ranging and widely applicable – is being provided to those involved or impacted by the manufactured housing industry, which in the 21st century has been oddly underperforming despite the fact that individuals hold roles in corporate and association/nonprofit roles that by defintion are fiduciary duties where self-dealing and conflicts of interests are routinely barred.

Manufactured housing is a heavily regulated industry. There are numerous laws that apply. Manufactured housing also has the benefit of certain laws which will be addressed further below.

The reputation of Harvard University is perhaps not as sterling today as it was nearly a quarter of a century ago when a Harvard researcher in their Joint Center for Housing Studies (JCHS) said the following about manufactured housing. Per Eric Belsky, the former Executive Director for Harvard’s JCHS: “there are multiple reasons to expect manufactured housing to do better than site built housing in the decade.” That quote is per the source as noted below.

But instead of going up, manufactured housing slumped dramatically from its mid-to-late 1990s production levels.

While estimates of the number of housing units vary widely, with some saying it is as low as 4 million units, to thers saying it is more in the range of 7 to 10 million units, it is worth noting that the slump in manufactured housing may account for perhaps half of that shortfall had production simply stayed roughly level to what was achieved in the mid-to-late 1990s. As was mentioned above, Congress enacted legislation in 2000 and 2008 that was specifically designed to help manufactured housing. So, the slump since 2000 ought to cause public officials, taxpayers, and others interested in solving the affordable housing crisis to lean in and ask: why? Why did manufactured housing decline?

There are several factors. But those questions, facts, evidence, and related concerns serve as part of the backdrop for this article.

AI

Artificial intelligence (AI) is ‘experimental,’ as several sources state. Having used AI for nearly two years in clearly disclosed contexts on MHProNews, and also on MHLivingNews, there are times that AI provides slanted, inaccurate, or problematic answers. For example, left-leaning Google’s Gemini carries the disclosure for several of the Q&As that will follow: “Generative AI is experimental. For legal advice, consult a professional.” While MHProNews provides clearly sourced information and attributions, and makes reasonable attempts to avoid sharing misinformation, that disclaimer would apply here too. That said, when MHProNews contacts an attorney or corporate official for a business, corporation, or nonprofit, it is hard to picture a time where they directly disputed the premise. FWIW, attorneys and public officials are among our regular readers.

There are an array of ways that a lack of affordable manufactured housing impacts consumers, taxpayers, investors, public officials, our industry’s professionals, and most others. While MHProNews is a public critic of Cavco Industries (CVCO) and several of the dominating brands at the Manufactured Housing Institute (MHI), this screen capture below from Cavco’s Investor Relations (IR) presentation provides a useful snapshot of why manufactured housing is important to the U.S., and why the headline topics detailed herein matter. More on that item from Cavco later in this FEA report.

With that brief backdrop, here are the following definitions and descriptions and their sources.

Part I – What is a Fiduciary? Do Nonprofit Board Members have a Fiduciary Duty? 

Per CFPB – fiduciary.

A fiduciary is someone who manages money or property for someone else. When you’re named a fiduciary and accept the role, you must – by law – manage the person’s money and property for their benefit, not yours. Jun 27, 2023

What is a fiduciary? | Consumer Financial Protection Bureau

Question posed by MHProNews to left-leaning Google’s AI (Gemini).

Does a non profit board member have a fiduciary duty?

Yes, nonprofit board members have a fiduciary duty to the organization they serve. This duty requires them to act in the best interests of the nonprofit, prioritizing its mission and assets. Specifically, board members have the following fiduciary responsibilities:

1. Duty of Care: Board members must exercise reasonable care and diligence in their decision-making, staying informed about the organization’s activities and finances. This includes attending meetings, participating in strategic planning, and reviewing financial reports.
2. Duty of Loyalty: Board members must act in the best interests of the organization and avoid conflicts of interest. They should not prioritize their personal or professional interests over those of the nonprofit.
3. Duty of Obedience: Board members must ensure the organization complies with applicable laws, regulations, and its own governing documents, such as bylaws.

By fulfilling these fiduciary duties, board members help ensure the organization’s continued success and accountability.

A more detailed explaination provided by Google’s Gemini is as follows.

A fiduciary is a person or entity, like a guardian or trustee, who has a legal and ethical obligation to act in the best interests of another person or entity, known as the beneficiary. This duty typically involves managing money, property, or other assets for the benefit of the beneficiary.

Here’s a more detailed explanation:

Key Responsibilities:

• Acting in Good Faith:

Fiduciaries must act honestly and responsibly, prioritizing the beneficiary’s interests over their own.

• Duty of Care:

They must exercise reasonable care and diligence in managing the beneficiary’s assets.

• Duty of Loyalty:

They must avoid conflicts of interest and ensure that the beneficiary’s interests are not harmed by any actions they take.

• Duty of Disclosure:

They must keep the beneficiary informed about their actions and the status of the assets they are managing.

Examples of Fiduciaries:

• Trustee: Manages assets for the benefit of beneficiaries under a trust agreement.
• Guardian: Acts on behalf of a minor or incapacitated adult, making decisions about their care and property.
• Executor or Administrator: Manages an estate after the death of an individual.
• Lawyer: Represents a client’s interests in legal matters.
• Company Board of Directors: Manages the company in the best interest of the shareholders.

Important Considerations:

• A fiduciary relationship involves a high degree of trust and confidence.

• Fiduciaries can face legal consequences for failing to fulfill their duties, known as breach of fiduciary duty.

• In many cases, fiduciaries are required to act in the best financial interests of the beneficiary, according to NerdWallet.

Part II – What is Self Dealing?

Self Dealing per left-leaning Wikipedia.

Self-dealing is the conduct of a trustee, attorney, corporate officer, or other fiduciary that consists of taking advantage of their position in a transaction and acting in their own interests rather than in the interests of the beneficiaries of the trust, corporate shareholders, or their clients. According to the political scientist Andrew Stark, “[i]n self-dealing, an officeholder’s official role allows her to affect one or more of her own personal interests.” It is a form of conflict of interest.^[1]

Self-dealing may involve misappropriation or usurpation of corporate assets or opportunities. Political scientists Ken Kernaghan and John Langford define self-dealing as “a situation where one takes an action in an official capacity which involves dealing with oneself in a private capacity and which confers a benefit on oneself.”^[2]

…

Where a fiduciary has engaged in self-dealing, this constitutes a breach of the fiduciary relationship. The principal of that fiduciary (the person to whom duties are owed) may sue and both recover the principal’s lost profits and disgorge the fiduciary’s wrongful profits.

In the United States, repeated self-dealing by a private foundation can result in the involuntary termination of its tax-exempt status.^[4]

What is Self-Dealing per Gemini

Self-dealing refers to a situation where a person in a position of trust, like a trustee, corporate officer, or fiduciary, uses that position to benefit themselves, rather than the beneficiaries of the trust, shareholders, or clients. This can involve engaging in transactions where their personal interests conflict with their duties, or acting in a way that prioritizes their own gain over the interests of those they are obligated to serve.

Here’s a more detailed breakdown:

• Conflict of Interest:

Self-dealing is inherently a conflict of interest. The fiduciary is in a position where their personal interests and their duty to act in the best interests of others clash.

• Breach of Duty:

It’s a breach of fiduciary duty, which is a legal and ethical obligation to act in the best interests of others.

• Potential for Abuse:

This can lead to the abuse of power and the exploitation of beneficiaries.

• Examples:

• • A trustee selling trust assets to themselves.

• • A corporate officer using company resources for personal gain.

• • A financial advisor recommending investments that benefit them personally, even if they are not the best for the client.

• Penalties:

Self-dealing can lead to serious consequences, including fines, restitution, and potentially even imprisonment.

• Legal and Ethical Implications:

It’s a violation of both law and ethics, as fiduciaries are held to high standards of integrity and loyalty.

Part III – What does the FBI (Federal Bureau of Investigations) Do?

MHProNews notes that among the items from the FBI website that follows is that the federal agency investigates “White-Collar Crime” and “Public Corruption.”  While the FBI has been under fire for years, and that should be taken into account as one considers the following, they have nevertheless made arrests that involve public corruption of higher profile figures such a former U.S. Senator Robert “Bob” Menendez (NJ-D).  The more recently have made the arrest of two judges who purportedly obstructed justice or harbored with respect to illegal aliens.  President Trump named Kash Patel and Dan Bongino as the new director and deputy director of the organization the pledge is that reforms are coming. MHProNews notes that some of the terminology on this page may change as Patel and Bongino begin what is part of a promised reform of the FBI.

Former Senator Menendez was a Democrat. While controversial at the time, former Rep. George Santos (R) was expelled by fellow Republicans from Congress, even though they held a slim majority.  Republicans may feel better about that step now than at the time. Santos was convicted of criminal activity recently.

Two pull quotes from a longer Gemini reply.

“Two judges were recently charged in immigration cases: Milwaukee County Circuit Judge Hannah Dugan and a former New Mexico judge.”

So, while the legal system has long been ‘charged’ by pundits, politicos, and members of the public with weaponization and politicization, the system arguably can and does work in some cases. There will be more about big white collar crime cases further below.

With that backdrop, per the FBI website on 4.26.2025 is the following.

Terrorism

To counter terrorism, the FBI’s top investigative priority, we use our investigative and intelligence capabilities to neutralize domestic extremists and help dismantle terrorist networks worldwide.

Cybercrime

The FBI is the lead federal agency for investigating cyberattacks by criminals, overseas adversaries, and terrorists. The threat is incredibly serious—and growing.

Counterintelligence

The FBI is the lead agency for exposing, preventing, and investigating intelligence activities, including espionage, in the U.S.

 

Civil Rights

The FBI, the lead agency for enforcing civil rights law, aggressively investigates hate crime, color of law abuses by public officials, human trafficking and involuntary servitude, and freedom of access to clinic entrances violations.

Public Corruption

Public corruption is the FBI’s top criminal investigative priority, that includes border corruption, election crimes, international corruption and prison corruption.

Weapons of Mass Destruction

The Weapons of Mass Destruction Directorate investigates and works to prevent incidents involving nuclear, radiological, biological, or chemical weapons.

Transnational Organized Crime

The FBI is dedicated to eliminating transnational organized crime groups that pose the greatest threat to the national and economic security of the United States.

Violent Crime

The FBI, with its law enforcement partners, plays a key role in combating violent crime involving gangs, crimes against children, crimes in Indian Country, fugitives and missing persons, kidnappings, and bank robberies.

White-Collar Crime

These crimes are not violent, but they are not victimless. White-collar crimes can destroy a company, wipe out a person’s life savings, cost investors billions of dollars, and erode the public’s trust in institutions.

Environmental Crime

The FBI investigates criminal cases that have violated U.S. laws intended to protect the environment, human health, worker safety, and animal welfare.

How We Investigate

Whether it’s the hostage rescue team or the latest intelligence, FBI personnel have a variety of tools and tactics in their investigative toolboxes to keep the public safe.

Part IV MHProNews Q&A on SEC Materiality and Manufactured Housing Institute and Specific MHI Member Brands related.

Google’s Gemini, or other AI powered platforms for that matter, are imperfect but may at times produce surprisingly good information. That may be particularly true if you know what the answer should be (based on prior research, experience, other knowledge) and double check to make sure that the results are relevant.  That said, as has been documented by MHProNews and others online, there are times AI glitches. The response below is the 2nd answer, not the first, because the first answered had what appeared to be a factual error. That was pointed out in a follow up, and Gemini re-ran its research inquiries, and produced the following.

There is a chart below that Gemini left blank the connection between the two men named and what their ties were to various MHI linked insider brands. MHProNews is hereby providing those insights which are not in the Gemini original, as will be seen further below.

Leo Poggione – Former [MHI] Chairman [of the board] – Poggione‘s business was purchased by Cavco Industries (CVCO). 

Tom Hodges – Former [MHI] Chairman [of the board] – Hodges is the General Counsel for Berkshire Hathaway (BRK) owned Clayton Homes. 

PDF of the following from Gemini is linked here.

The screen capture of the Q&A thread with MHProNews that produced this response by Gemini is linked here. The start of the initial question and the response of Gemini’s plan is as shown.

Validity of SEC Materiality Guidance and Allegations Against Manufactured Housing Institute Members

1. Executive Summary

This report analyzes the current validity of the Securities and Exchange Commission (SEC) guidance on materiality, specifically focusing on a document authored by Paul Munter in March 2022. The analysis confirms that this guidance, centered on the “reasonable investor” standard, remains valid, consistent with Supreme Court precedent and further elaborated upon in subsequent SEC communications. Furthermore, the report examines evidence-based arguments, primarily from MHProNews and MHLivingNews, alleging market manipulation, conflicts of interest, and self-dealing by certain members of the Manufactured Housing Institute (MHI). The evidence suggests a pattern of behavior that may prioritize the interests of larger, consolidation-focused members, potentially to the detriment of the broader manufactured housing industry and affordable housing initiatives. While MHI and the implicated parties have issued statements on some related issues, comprehensive public responses directly addressing these specific allegations have been largely absent. Notably, several antitrust lawsuits have been filed against prominent MHI members, indicating legal scrutiny of their business practices.

1. Analysis of SEC Guidance on Materiality

II.A. Verification of Current Validity

To ascertain the ongoing validity of the SEC guidance on materiality, as presented in the document from manufacturedhomepronews.com, an examination of the official SEC website (www.sec.gov) was conducted. The mission of the SEC is to protect investors, maintain fair, orderly, and efficient markets, and facilitate capital formation. A key mechanism for achieving this mission is requiring public companies to disclose meaningful financial and other information to the public, allowing investors to make informed decisions.

The document in question is a statement titled “Assessing Materiality: Focusing on the Reasonable Investor When Evaluating Errors,” made by Paul Munter, then Acting Chief Accountant, in March 2022. This statement emphasizes the importance of an objective assessment of materiality from the perspective of a reasonable investor, considering the “total mix” of information available.

Subsequent SEC actions and statements indicate that the core principles outlined in Munter’s 2022 statement remain in effect. For instance, in March 2024, the SEC issued a final rule requiring climate-related disclosures, which also referenced the concept of materiality, consistent with Supreme Court precedent. These updates, while focused on a specific area of disclosure, reiterate the fundamental definition of materiality as information that a reasonable investor would consider important when making investment or voting decisions.

Furthermore, a March 2024 article discussing the SEC’s materiality guidance noted that experts believe the definition has largely worked as intended, though better training on its application might be necessary. This suggests the continued relevance of the existing framework. Paul Munter himself, in a December 2023 statement, again highlighted the importance of an objective analysis from the perspective of a reasonable investor when evaluating the materiality of errors in the statement of cash flows. This reinforces the ongoing significance of the principles he articulated in his March 2022 statement. Additionally, the March 2022 statement is referenced in a PCAOB document from April 2024, indicating its continued relevance within the broader regulatory landscape. Analyses from legal and accounting firms following the March 2022 statement also confirm its emphasis on objectivity, the “reasonable investor,” and the consideration of both quantitative and qualitative factors.

Based on this review, Paul Munter’s March 2022 statement on assessing materiality appears to still represent valid guidance from the SEC. While new rules and interpretations in specific areas like climate change have emerged, the core definition and principles remain consistent with this earlier guidance and established legal precedent.

II.B. Prevailing Definition and Interpretation of Materiality

The prevailing definition of materiality in financial reporting, as emphasized by the SEC and supported by Supreme Court precedent, centers on the “reasonable investor” standard. This means that information is considered material if there is a substantial likelihood that a reasonable investor would view the omission or misstatement of that information as significantly altering the total mix of information made available. The assessment of materiality requires considering the “total mix” of information, not just isolated facts.

Crucially, materiality is not determined solely by quantitative thresholds, such as a specific percentage of net income. While quantitative benchmarks can serve as an initial step in assessing materiality, a full analysis must also consider various qualitative factors. Staff Accounting Bulletin (SAB) No. 99 explicitly states that misstatements are not immaterial simply because they fall below a certain quantitative threshold and provides examples of qualitative circumstances that may affect materiality.

The SEC staff has consistently emphasized the need for an objective assessment of materiality from the perspective of a reasonable investor, urging registrants, auditors, and audit committees to avoid any bias that might be inconsistent with this perspective. This includes avoiding rationalizations for treating quantitatively significant errors as immaterial based on qualitative considerations alone.

When an error is identified in previously issued financial statements, the determination of its materiality dictates the corrective action. A material error requires restatement of prior-period financial statements, often referred to as a “Big R” restatement. If the error is not material to prior periods but would be material if not corrected in the current period, it can be corrected through a revision in the current period, known as a “little r” restatement. The SEC staff has observed an increase in “little r” restatements and continues to monitor this trend, emphasizing the importance of proper materiality assessments.

III. Evidence of Market Manipulation by MHI Members

III.A. Analysis of Allegations from MHProNews and MHLivingNews

MHProNews and MHLivingNews have published numerous articles and reports alleging market manipulation by certain members of the Manufactured Housing Institute (MHI). A central theme in these allegations is the significant underperformance of the manufactured housing industry in the 21st century, particularly when compared to its historical production levels and the current affordable housing crisis. Production plummeted from 373,143 units in 1998 to 103,314 in 2024.

The allegations suggest that MHI’s dominant members, often large, vertically integrated companies, may be benefiting from this underperformance through industry consolidation. It is claimed that MHI has not effectively advocated for policies that would promote broader industry growth, such as the robust enforcement of the “enhanced preemption” provision of the Manufactured Housing Improvement Act of 2000, which could override discriminatory local zoning regulations that often restrict the placement of manufactured homes. The Manufactured Housing Association for Regulatory Reform (MHARR) has often presented a contrasting view, advocating for more aggressive enforcement of existing laws and criticizing MHI’s approach.

III.B. Analysis of Sam Zell’s “Oligopoly” Quote

The statement by Sam Zell in 2013, “We like the oligopoly nature of our business,” 1 made in the context of his investment in manufactured housing through Equity LifeStyle Properties (ELS), is frequently cited in the allegations of market manipulation.3 Zell’s company, Equity LifeStyle Properties (ELS), is a major owner and operator of manufactured home communities and a prominent member of MHI.3 An oligopoly, by definition, is a market structure with a small number of large sellers, which can lead to reduced competition and potentially higher prices. Zell’s explicit preference for this market structure within the manufactured housing industry aligns with the allegations that certain dominant players may be acting to limit competition and consolidate their market power.3

III.C. ELS Acquisition of Datacomp, MHVillage, and MHInsider

In December 2021, Equity LifeStyle Properties (ELS) acquired MHVillage and Datacomp for $43 million.9 MHVillage is a prominent online marketplace for buying and selling manufactured homes, while Datacomp provides market-based valuations for manufactured homes in land-lease communities.9 This acquisition also included MHInsider, a print and online magazine for manufactured housing industry professionals.11 The acquisition of Datacomp is particularly relevant given the ongoing antitrust lawsuits alleging that Datacomp’s data was used by several large community owners, including ELS, to coordinate and inflate lot rental prices.17 These lawsuits claim that by sharing non-public, competitively sensitive information through Datacomp’s JLT Market Reports, these companies conspired to raise rents, harming residents and violating antitrust laws.21 The fact that ELS, a major player in the manufactured housing community sector and a defendant in these suits, now owns Datacomp raises further concerns about potential conflicts of interest and the integrity of market data within the industry.5

III.D. Discrepancy in Manufactured Housing Community Count

There is a notable discrepancy in the reported number of manufactured housing communities (MHCs) in the United States. While MHVillage, a platform now owned by ELS and often cited by MHI, reports around 43,000 to 44,000 communities31 other sources suggest a significantly higher number. George McCarty of the Lincoln Institute of Land Policy, a non-profit private operating foundation35 has stated that there are over 50,000 such land-lease properties.3 Similarly, FEMA (Federal Emergency Management Agency) data related to disaster housing assistance has also indicated figures exceeding 50,000 for mobile home parks and manufactured housing communities.36 This difference in reported numbers raises questions about the accuracy of data relied upon by MHI and its potential implications for understanding the true scope and impact of the manufactured housing sector, particularly in addressing the affordable housing crisis.32 The undercounting of communities could potentially minimize the perceived need for policy changes or regulatory oversight.

III.E. MHInsider’s Role and Potential Bias

MHInsider, a publication owned by MHVillage which is now part of ELS, serves as a news source for manufactured housing professionals and is endorsed by MHI.40 Given the ownership structure, concerns have been raised about potential bias in its reporting, particularly regarding MHI and its dominant members like ELS.45 Allegations suggest that MHInsider may not provide comprehensive or critical coverage of issues such as the underperformance of the industry, regulatory barriers, or the antitrust allegations facing MHI members.45 This lack of critical analysis could serve to enhance the credibility of MHI and its insiders by presenting a more positive or less challenging narrative.42 The absence of disclosed ownership in some instances has also been noted as a potential issue of transparency.47 The “illusory effect” refers to the tendency for people to believe information presented in a seemingly professional or authoritative format, even if the content is biased or incomplete. MHInsider’s position as an industry publication could lend credence to MHI’s messaging, potentially influencing the perceptions of industry professionals, investors, and the public.

1. Evidence of Conflicts of Interest by MHI Members

IV.A. Review of Board Member Lists and MHI Form 990

The provided lists of MHI board members reveal significant overlap between MHI leadership and executives from major manufactured housing companies. Kevin Clayton, President and Chief Executive Officer of Clayton Homes, has served as Secretary for the Executive Committee of MHI.[https://www.manufacturedhomepronews.com/wp-content/uploads/2024/02/ManufacturedHousingInstituteMHIboard-ExecutiveCommitteeCurrentAndPriorYears-minManufacturedHomeProNewsMHProNews.png] Other prominent MHI board members include representatives from companies like Cavco Industries and Equity LifeStyle Properties [https://www.manufacturedhomepronews.com/wp-content/uploads/2024/02/ManufacturedHousingInstituteMHIboard-ExecutiveCommitteeCurrentAndPriorYears-minManufacturedHomeProNewsMHProNews.png]. This concentration of leadership from the largest industry players within MHI raises concerns about potential conflicts of interest, where decisions made by MHI might favor these dominant companies.48

Analysis of MHI’s Form 990, a tax form for non-profit organizations, could provide further insights into the organization’s mission and priorities.(https://www.manufacturedhomepronews.com/wp-content/uploads/2025/04/ManufacturedHousingInstituteMissionStatementPerIRSform990SignedByRichardDickJennisonPresCEOManHousingInstMHProNewsFactCheck.jpg) MHI’s stated mission is to serve its membership by providing industry research, promotion, education, and government relations programs, and by building and facilitating consensus within the industry.57 However, allegations suggest that MHI’s actions may not always align with the interests of all its members or the broader goal of expanding affordable homeownership, potentially indicating a conflict between its stated mission and the interests of its dominant members.50 Information regarding top staff pay revealed in these documents [https://www.manufacturedhomepronews.com/over-1-million-manufactured-housing-institute-doc-drop-top-mhi-staff-pay-revealed-additionally-unpacking-evidence-of-perjury-fraud-other-possible-federal-crimes-plus-mhville-stocks-upda] might also shed light on the organization’s priorities.

IV.B. Lobbying Activities and Dual Roles

Allegations have been made regarding potential conflicts of interest arising from the lobbying activities of MHI CEO Lesli Gooch.48 Reports suggest that while serving as CEO of MHI, Gooch also engaged in lobbying for organizations representing conventional home builders.48 This dual role raises questions about whether MHI’s advocacy efforts are solely focused on promoting the interests of the manufactured housing industry or if they are potentially influenced by the interests of other housing sectors.48 Such a conflict could undermine MHI’s effectiveness in advocating for policies that would benefit manufactured housing and expand affordable homeownership.48

1. Evidence of Self-Dealing by MHI Members

V.A. Scrutiny of Financial Transactions and Relationships

The close relationship between Berkshire Hathaway, its subsidiaries like Clayton Homes, Vanderbilt Mortgage, and 21st Mortgage, and MHI leadership has fueled allegations of self-dealing.17 Warren Buffett’s pledge to Kevin Clayton regarding access to capital suggests a level of financial support that could give Clayton Homes a significant advantage over competitors.79 Allegations indicate that Berkshire-owned lenders may have engaged in predatory practices, potentially steering borrowers towards higher-cost loans that benefit the company.86 The dominant market share held by Clayton Homes and its affiliated lenders, coupled with the leadership roles within MHI, creates an environment where self-dealing could occur, potentially at the expense of independent retailers, smaller manufacturers, and consumers seeking affordable housing.108

1. Impact on Investors and Industry Members

The alleged market manipulation, conflicts of interest, and self-dealing by certain MHI members could have significant negative impacts on investors and other industry participants. Investors in publicly traded manufactured housing companies, particularly smaller independent firms, might experience lower returns if the market is being artificially constrained to benefit a few large players.108 Independent retailers and smaller manufacturers could face unfair competition and barriers to growth in a market dominated by vertically integrated giants with significant financial advantages and potential influence over industry standards and regulations.108 Community owners not aligned with the dominant players might also be disadvantaged.

Furthermore, these alleged practices could harm the availability and affordability of manufactured housing for consumers.108 If competition is stifled and market consolidation is prioritized, consumers might face fewer choices and potentially higher prices for manufactured homes. The failure to effectively advocate for policies that would expand access to manufactured housing, such as zoning reform and improved financing options, further exacerbates the affordable housing crisis.108 MHI’s mission statement emphasizes serving its membership and expanding attainable homeownership.57 The alleged actions raise questions about whether the interests of all members and the goal of affordable housing are truly being served.50

VII. Responses from MHI and Involved Parties

VII.A. Public Statements and Press Releases

While MHI and the involved companies have issued public statements on certain related issues, comprehensive responses directly addressing the specific allegations of market manipulation, conflicts of interest, and self-dealing detailed by MHProNews and MHLivingNews have been largely absent. For example, Clayton Homes has issued press releases responding to a lawsuit filed by the CFPB 90, denying the allegations of predatory lending.90 MHI has also engaged in legal action against the Department of Energy regarding energy efficiency standards for manufactured homes.155 However, these responses do not directly address the broader claims of market manipulation and anticompetitive behavior within the industry. In many instances, MHI and the named individuals and companies have declined to comment on the specific allegations raised by MHProNews and MHLivingNews.156

VII.B. Responses to MHProNews’ Public Outreaches

MHProNews has documented several instances of publicly reaching out to MHI leaders and affiliated brands for comment on these allegations and their performance [https://www.manufacturedhomepronews.com/masthead/4-quick-documented-examples-of-manufactured-housing-institute-leaders-publicly-ducking-out-on-explaining-their-performance-or-lack-thereof-els-howard-walker/],(https://www.manufacturedhomepronews.com/wp-content/uploads/2025/04/MHProNewsEmailedInquiryCavcoCEO-WilliamBillBoor-MHI-ChairmanMHI-CEO-LesliGooch-MHARR-PresCEO-MarkWeiss-DannyGhorbani-MHI-LinkedBloggerGeorgeF.Allen-MHLivingNewsFactCheckAnalysis.png)], and.48 In many of these documented outreaches, MHI and its leaders have either declined to comment or have remained silent, leading to the perception that they are “ducking out” on explaining their performance or addressing the allegations.48 This lack of engagement contributes to concerns about transparency and accountability within the organization and the industry.48

VII.C. Antitrust Litigation and RICO/Hobbs Act Allegations

Several class-action antitrust lawsuits have been filed against prominent MHI members, including Equity LifeStyle Properties (ELS), Sun Communities, Datacomp Appraisal Systems, and others [https://www.manufacturedhomepronews.com/two-more-class-action-antitrust-suits-hit-high-profile-manufactured-housing-institute-members-and-mhi-state-affiliate-members-towsend-in-case-no-123-cv-16462-and-muns-pleadings-and-analysis/] and.17 These lawsuits, such as Townsend v. Datacomp Appraisal Systems, Inc. et al. and Muns v. Datacomp Appraisal Systems, Inc. et al., allege a conspiracy to fix, raise, maintain, and/or stabilize manufactured home lot rental prices, potentially violating Section 1 of the Sherman Act.23 MHI itself has not been consistently named as a defendant in all these suits, but the involvement of numerous high-profile members underscores the legal scrutiny of business practices within the industry. The status of these legal proceedings is ongoing.28

Additionally, some articles and research published by MHProNews and MHLivingNews have raised allegations of potential RICO (Racketeer Influenced and Corrupt Organizations Act) and Hobbs Act violations.156 These allegations, while not necessarily the subject of formal legal charges at this point, indicate the seriousness of the concerns being raised about the conduct of certain MHI members and their potential impact on the manufactured housing industry.

VIII. Conclusion

The analysis indicates that the SEC guidance on materiality, as outlined in Paul Munter’s March 2022 statement, remains a valid framework for assessing the significance of information to investors. This guidance emphasizes the “reasonable investor” standard and the importance of considering both quantitative and qualitative factors within the “total mix” of available information.

Regarding the allegations against certain MHI members, there is an evidence-based argument to be made for potential market manipulation, conflicts of interest, and self-dealing. This argument is supported by:

• The persistent underperformance of the manufactured housing industry despite a clear demand for affordable housing.
• The statement by Sam Zell expressing a preference for the “oligopoly nature” of the business.3
• Third-party research suggesting market foreclosure and the use of “sabotaging monopoly” tactics within the industry.112
• ELS’s acquisition of Datacomp, MHVillage, and MHInsider and the antitrust concerns surrounding Datacomp’s role in alleged price-fixing.5
• The discrepancy in the reported number of manufactured housing communities between MHVillage/MHI and other sources like FEMA and George McCarty.31
• Concerns about potential bias and lack of critical coverage in MHInsider, given its ownership by ELS.45
• The overlap in leadership between MHI and major manufactured housing companies, raising concerns about conflicts of interest[https://www.manufacturedhomepronews.com/wp-content/uploads/2024/02/ManufacturedHousingInstituteMHIboard-ExecutiveCommitteeCurrentAndPriorYears-minManufacturedHomeProNewsMHProNews.png].
• Allegations of MHI’s CEO lobbying for potentially competing interests.48
• Reports of potentially predatory lending practices by a major MHI member.86
• The existence of multiple class-action antitrust lawsuits against prominent MHI members [https://www.manufacturedhomepronews.com/two-more-class-action-antitrust-suits-hit-high-profile-manufactured-housing-institute-members-and-mhi-state-affiliate-members-towsend-in-case-no-123-cv-16462-and-muns-pleadings-and-analysis/].17

MHI and the involved parties have largely not provided comprehensive public responses to these specific allegations, particularly those detailed by MHProNews and MHLivingNews. There are documented instances of MHI leaders declining to comment or engage with inquiries on these matters [https://www.manufacturedhomepronews.com/masthead/4-quick-documented-examples-of-manufactured-housing-institute-leaders-publicly-ducking-out-on-explaining-their-performance-or-lack-thereof-els-howard-walker/],(https://www.manufacturedhomepronews.com/wp-content/uploads/2025/04/MHProNewsEmailedInquiryCavcoCEO-WilliamBillBoor-MHI-ChairmanMHI-CEO-LesliGooch-MHARR-PresCEO-MarkWeiss-DannyGhorbani-MHI-LinkedBloggerGeorgeF.Allen-MHLivingNewsFactCheckAnalysis.png)],.

The evidence suggests a need for greater transparency and accountability within the manufactured housing industry. Investors, industry members, and regulators should carefully consider these allegations and the supporting evidence to ensure fair market practices and the expansion of affordable housing options.

Table 1: Overlap in Leadership Between MHI and Major Manufactured Housing Companies

Note: This table is based on the provided documents and may not represent the complete current leadership structure.

Table 2: Summary of Antitrust Lawsuits Against MHI Members

Note: This table summarizes the key antitrust lawsuits mentioned in the provided documents. There may be other ongoing litigation.

Table 3: Documented Instances of MHProNews’ Outreach and MHI/Member Responses (Examples)

Note: This table provides examples based on the provided links and reports. It is not an exhaustive list.

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Part V – Follow up MHProNews Q&A with Gemini AI.

The inquiry is by this writer for MHProNews. The response is from Gemini on 4.26.2025.

Gemini, is there evidence to support the claim that MHProNews relies heavily on facts, evidence, and third-party generated information that it does expert analysis on in a manner that thousands of manufactured home industry professionals find compelling and turn to for news and views that is reliable? Does MHProNews/MHLivingNews accurately quote facts, clearly cite sources, and provides clearly labeled analysis and comemntary that has made MHProNews the largest and most read trade media in manufactured housing?

Sources and related content

Professional Manufactured Home Industry Outsiders Remarks and Insider Rants on Good Umbrella Trade Qualities Reveal Woes at Manufactured Housing Institute for Organic Growth-Minded MHVille Leaders-FEA – MHProNews

www.manufacturedhomepronews.com

 

Manufactured Housing Misses-Experts and Insiders Critique MHI Failures | Lakeland, FL Patch

patch.com

 

Manufactured Home Groups Split in Transparency Amidst Housing Crisis | Lakeland, FL Patch

Manufactured Home Groups Split in Transparency Amidst Housing Crisis | Lakeland, FL Patch

patch.com

 

Maris Jensen Univ Study ‘Market Foreclosure in Manufactured Housing’ –Antitrust Violation Alarms– ‘Distort Competition to Monopoly Outcome’ Named Specific Manufactured Housing Institute Firms – MHProNews

www.manufacturedhomepronews.com

 

Affordable Manufactured Home History-Associations-21st Century Scandal | Lakeland, FL Patch

patch.com/florida/lakeland/affordable-manufactured-home-history-associations-21st-century-scandal

Part VI – Additional Observations, Closing Thoughts, and Additional Reading.

1)

Part of a longer follow up to the above, Gemini – having reviewed the draft version of this article – suggested the following.

Based on the research material, Part I might begin by establishing the significance of the manufactured housing industry, perhaps in the context of the affordable housing crisis. Articles on MHProNews often address the industry’s role and challenges, including legislative developments and the stances of various industry associations. Therefore, Part I could set the stage by outlining the current landscape of the manufactured housing sector and its importance, thereby providing a relevant backdrop for the subsequent discussion of legal and ethical obligations.  

Hmmm…okay, perhaps fair enough. MHProNews did provide an illustration from Cavco Industries (see the preface, before Part I). A few added illustrations and related can be useful.

2) As has been mentioned hundreds of times on MHProNews and MHLivingNews before, manufactured housing benefits from certain federal laws that aimed to boost manufactured home production and sales. Why? Because Congress, often after years of study, determined that manufactured homes were a unique form of unsubsidized housing that can be used to solve the U.S. affordable housing crisis.  Some relevant articles, beyond the research documents found in article below the illustration above, could be the following. Note that dozens of references by Gemini (shown in Part IV above) are from MHProNews/MHLivingNews. Neither that, nor what follows, is exhaustive.

• For a relatively focused snapshot of why the industry is underperforming during an affordable housing crisis were 7 minutes of hot linked remarks by MHProNews’ L. A. “Tony” Kovach as an expert presenter to an FHFA listening session linked here. Note that MHI, MHARR, and several public officials and other nonprofits, attorneys, and professionals were present for that Kovach statement which was featured for some time on the FHFA website.

Friday Flashback and Fast-Forward – ‘the Manufactured Home Solution vs Manufactured Home Problem’ plus ‘Manufactured Housings Problems and Solutions in a Nutshell’ – MHVille FEA

There are reasons why AI has said that MHProNews has more than 6x the combined readership of MHI and its affiliated bloggers and trade media.

Again, our thanks to free email subscribers and all readers like you, as well as our tipsters/sources, sponsors and God for making and keeping us the runaway number one source for authentic “News through the lens of manufactured homes and factory-built housing” © where “We Provide, You Decide.” © ## (Affordable housing, manufactured homes, reports, fact-checks, analysis, and commentary. Third-party images or content are provided under fair use guidelines for media.) See Related Reports. Text/image boxes often are hot-linked to other reports that can be access by clicking on them.)

By L.A. “Tony” Kovach – for MHProNews.com.

Tony earned a journalism scholarship and earned numerous awards in history and in manufactured housing.

For example, he earned the prestigious Lottinville Award in history from the University of Oklahoma, where he studied history and business management. He’s a managing member and co-founder of LifeStyle Factory Homes, LLC, the parent company to MHProNews, and MHLivingNews.com.

This article reflects the LLC’s and/or the writer’s position and may or may not reflect the views of sponsors or supporters.

http://latonykovach.com

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

https://www.manufacturedhomepronews.com/nahb-praises-trump-grok-the-affordable-housing-crisis-isnt-just-market-failure-its-an-orchestrated-squeeze-mhi-playing-both-sides-and-hud-asleep-at-the-wheel/