MHARR, MHI and GSE Reform, Background to Danny Ghorbani’s release and George Allen’s Planned “Story”

mhpronews-mharr-mhi-associations-graphic-manufactured-home-marketing-sales-managementOn Sunday, March 16 at 4:47 PM ET, a news release was received from the Manufactured Housing Institute (MHI) on the topic of the highly-charged issue of a Government Sponsored Enterprise (GSE, “Fannie and Freddie”) reform plan.

Some 3 Hours and 43 minutes later, at 8:30 PM on the same day, the first message came in from the Manufactured Housing Association for Regulatory Reform (MHARR) on the same topic. MHI’s full release on the topic of GSE reform is linked here, while the link to MHARR’s full release on the topic is found here.

In his message, MHARR’s President, Danny Ghorbani, claimed their “…calculated risk by MHARR that has now…” quoting their headline …achieves major victory.

While most industry professionals who follow these events would agree that this is certainly promising for consumers and the industry, the GSE reform legislation has a long way to go before it is becomes law. This is a one step along a longer path, as Ghorbani’s own statement from MHARR later acknowledges.

That fact begs the question, what makes this a bigger success than HR 1779 or S 1828, both of which are well underway?

It also raises the question, what was the “calculated risk” that Ghorbani’s message refers to in his release? Where is the “risk” in MHARR sending a position paper to the Senate Banking Committee?

Could it be that the “risk” Ghorbani refers to is that MHARR has not publicly supporting HR 1779 and S 1828? Isn’t it risky for their member-manufacturers and customers to not cover all possible legislative and lobbying bases, as MHI’s team has been doing on the finance and other issues?

MHARR claims MHI had a Single Focus

MHARR CEO Ghorbani’s message included this paragraph,

At a time when much of the industry was pursuing a singular focus on unsuccessful legislative modifications to the loan originator compensation and high-cost loan provisions of the Dodd-Frank finance reform law — and was unwilling to join MHARR in an  initiative on the much farther-reaching issue of GSE reform — the MHARR Board of Directors chose to advance the inclusion of all types of manufactured home loans and definitive action to end the discrimination that has dogged the industry’s consumer financing for decades, as part of the GSE reform process in Congress.”

As the numerous items that follow below demonstrate, the first part of this statement cited above is demonstrably in error. Namely:

At a time when much of the industry was pursuing a singular focus on unsuccessful legislative modifications to the loan originator compensation and high-cost loan provisions of the Dodd-Frank finance reform law –…”

Furthermore, as this Congressional legislative session is not yet over, none of these efforts – GSE Reform or Dodd-Frank reform – can be called a failure or a success.

So why is there a need for MHARR’s CEO to paint MHI’s efforts as a ‘failure,’ when the GSE effort is not as far along as HR 1779 or S. 1828?

Some MHARR officials and allied industry commentator in the dark?

Messages and calls from MHARR members, those aligned with MHARR and others outside of that camp to MHProNews seem to be unaware – or in some cases, won’t acknowledge – the fact that MHI has demonstrably been engaged on this topic of GSE reform for years, along with a variety of other issues in Washington. DC. Some examples will be shown in a down-loadable attachment, later below.

Agenda of Making MHI look bad, as a way of Making Ghorbani and Allen look more important?

broadside-darius-danny-ghorbani-president-mharr-george-allen-allen-letter-community-i ... actured-housing-institute-manufactured-housing-association-for-regulatory-reformOn Monday, after allegedly communicating with Danny Ghorbani, President and CEO at MHARR, George Allen sent an email to Rick Robinson, Vice President and General Counsel at MHI.

Robinson forwarded that email to Senior Vice President Jason Boehlert for response.

Allegedly, this email exchange has been shared with Ghorbani, Jim Visser, Ken Rishel and others linked to MHI and MHARR; and seems to accuse MHI of grabbing credit for work done by MHARR.

While sensational, the problem with this accusation by Allen against MHI, is that it flies in the face of the facts. But doesn’t this fit Allen’s self-description on his own blog of his activities? The word Allen used about himself, “agitate” includes the following definition from Google: “1) make (someone) troubled or nervous.”

The Google definition of agitator, is also insightful:

1. a person who urges others to protest or rebel.

synonyms: troublemaker, rabble-rouser, agent provocateur, demagogue, incendiary;

The Facts Say Differently

While some in the mix seem to take the position, ‘Don’t confuse me with facts, my mind is made up,’ a simple Google search demonstrates to the truth seeker that MHI has issued numerous updates on their activities in the GSE Reform arena.

A search of the articles published in the MHI News module demonstrates the same, and for those who attended the 2014 MHI Winter Meeting and Legislative Session, a briefing was given to attendee/members that coveted all of MHI’s lobbying and legislative initiatives, including GSE reform.

Clearly, MHI’s engagement on the GSE issue is a matter of public record and is no secret.

As MHProNews has documented in a series of articles, linked at the end of this report, George Allen has in his own words:

  • describes himself as one who agitates,

  • has gone from opposing Danny Ghorbani and calling him a flawed writer and leader, to now lauding him as a leader others should follow. The difference between recent and prior statements by Allen on Ghorbani?   Is it the MHARR paid ad and factories who Allen himself says are now paying Allen?

  • Allen has blasted MHI off and on for some two years for not buying him out when Allen wanted to retire.

Don’t such flip flops, contradictions, slanted ‘coverage’ and motivations beg a reasonable person to question the motivations and accuracy of Allen’s commentaries?

The Emails Between Allen and MHI – “We Provide, You Decide” ©

The exchange below is in a first-to-last message time sequence. They are word-for-word as the respective parties sent them, save the removal of the ‘signature (contact/disclaimers/resource)’ info at the end of each email and what amounts to ads from each of the respective emails. The typos in George Allen’s emails are in the original. The first message, as shown below, is to Rick Robinson at MHI.

Start of George Allen to Jason Boehlert at MHI Email Exchange

From: <gfa7156@aol.com<mailto:gfa7156@aol.com>>

Date: March 16, 2014 at 5:43:35 PM EDT

To: <info@mfghome.org<mailto:info@mfghome.org>>

Cc: <rrobinson@mfghome.org<mailto:rrobinson@mfghome.org>>

Subject: Re: MHI Housing Alert –  Senate Banking Committee Leaders Unveil GSE

Reform Plan – MHI Successfully Stakes out Ground for Manufactured Housing and

Personal Property Loans

Rick

When did MHI switch its’ primary legislative focus from Dodd-Frank regulatory
reform to GSE Reform? Didn’t seem to be that much of a priority during the
annual Legislative Conference last month in Arlington, VA. Here quoting directly
from this afternoon’s HOUSING ALERT from MHI:


“MHI Successfully Stakes Out Ground for Manufactured Housing and Personal
Property Loans” and “As advocated for by MHI, the legislative draft released by
the Committee includes language that would provide manufaturd home loans secured
by personal property with key access to a newly envisioned secondary market
mechanism.”

As exciting and hopeful as this news is, I’m wondering whether we’re indeed
reading/learning of a pure MHI effort to this much desired result, OR is there
more to this now quickly unfolding story, i.e. Is there someone else more
intimatly involved ‘in the mix’ who is NOT getting credit, in this email alert,
for drafting the language and lobbying for this legislative draft?

Frankly, I sense a story here….

GFA

George Allen


—–Original Message—–

From: Jason Boehlert <jBoehlert@mfghome.org>

To: GFA7156 <GFA7156@aol.com>

Cc: Richard Jennison <rjennison@mfghome.org>; Rick Robinson <rrobinson@mfghome.org>

Sent: Mon, Mar 17, 2014 11:32 am

Subject: RE: MHI Housing Alert – Senate Banking Committee Leaders Unveil GSE

Reform Plan – MHI Successfully Stakes out Ground for Manufactured Housing and

Personal Property Loans

George,

Thank you very much for your email.  However, I am unclear what you mean by “Is
there someone else more intimatly(sic) involved ‘in the mix’ who is NOT getting
credit, in this email alert, for drafting the language and lobbying for this
legislative draft?” We do not comment on the activities or actions of other
national organizations—that is not our role. Nor do we believe it serves the
interests of the industry or our members to do so.


Since MHI represents every facet of the industry—including builders, community
owners, lenders, supplier, retailers—our policy priorities are reflective of the
totality of our membership.  Dodd-Frank is a priority.  As are housing
finance/GSE reform, energy efficiency, tax, HUD Code and environmental issues
and we would never focus on one issue so persistently that it would be to the
detriment of the others. I know you did not attend, but GSE reform was
reaffirmed as an association policy priority during our legislative conference
and winter meeting and was discussed at length during the meeting of our
newly-formed government relations committee. The new government relations
committee has multiple representatives from each MHI division.


Expanding secondary market access for manufactured home loans, including those
secured by personal property has been a long-standing priority of MHI—dating
back to at least the duty-to-serve requirements that were included in the
Housing and Economic Recovery Act (HERA) in 2008.  We have, and continue to,
work with FHA, FHFA, Fannie Mae, Freddie Mac, Ginnie Mae, HUD, and the House
Financial Services and Senate Banking Committees to improve the availability of
financing options in the manufactured housing market, both from a residential
and commercial standpoint.

MHI represents every significant manufactured home lender in the industry and we
work hard to see that the totality of their interests—which are not limited to
Dodd-Frank/CFPB rule makings—are served.  Our efforts on GSE reform extend well
beyond the Senate Banking Committee’s recent legislative draft. If you are
suggesting that we have not been an active player in this regard, you are
mistaken. GSE reform has been an issue that has received very close attention
from our internal and external lobbying teams on an ongoing basis for several
years.

A sampling of our most recent activities include (but certainly not limited to):

· working with drafters of the underlying Corker-Warner bill (S.
1217)—which serves as the blueprint for the Senate Banking Committee bill—to
garner their approval for modifications of their measure that would expand
access for personal property loans

· communicating—both our internal and external lobbying teams—on an
ongoing basis with Democratic and Republican senior staff to the Senate Banking
Committee to include specific manufactured home/personal property language

·         providing key industry lending data to Senate staff to underscore the
need for specific statutory language

· facilitating an industry lender roundtable for Senate Banking
Committee staff—this panel of lenders, which represented the vast majority of
personal property manufactured home lending—provided the key information and
feedback needed by  committee staff to include manufactured home lending
provisions (which took place at our recent legislative conference)

· working to develop a consensus coalition position with consumer group
that are also seeking to expand personal property lending options for
manufactured housing

·  outreach to the Federal Housing Finance Agency (FHFA)—the
administration’s voice on GSE reform—to support legislative provisions expanding
manufactured home lending opportunities

· engaging an external lobbying firm whose principals include the most
recent Democratic Staff Director to the Senate Banking Committee (working
directly for Chairman Tim Johnson) and provided significant access to committee
staff drafting the legislation

As I hope you are aware, MHI’s involvement has not only been limited to the

Senate Bill. Our work also includes:

· facilitating the first-of-its-kind lending conference, sponsored by
then Rep. Joe Donnelly, in Elkhart, Indiana (which I believe you attended)

· improving the FHA Title I &II programs and opening Ginnie Mae to new
issuers (a work in progress)

· coordinating more than 1,000 comments in opposition to FHFA’s
duty-to-serve rule, which would ignore secondary market access for personal
property loans

· working to provide equal access for all mortgages in the House version
of GSE reform –the Path Act (which also includes specific MH relief from the
Dodd-Frank Act)

· testifying before Congress on three separate occasions over the past
three years on the need for secondary market access for manufactured home loans
secured by personal property—this does not include testimony provided prior to
2010 on the need to improve the FHA Title I & II programs for manufactured
housing

· more than 300 meetings conducted over the past three years with
Members of Congress specifically on the lack of credit access provided by the
GSEs for manufactured housing

· working directly with Fannie Mae and Freddie Mac to develop new
lending options for manufactured housing

I can only speak to the involvement of MHI, which has been continuous and
ongoing and substantial. Looking at the history, I think it is fair to say MHI
and its members have been leaders in working to expand manufactured housing
financing options for quite some time.

Best,
Jason


Jason Boehlert
Manufactured Housing Institute (MHI)
Senior Vice President of Government Affairs

________________________________________

From: gfa7156@aol.com [gfa7156@aol.com]

Sent: Monday, March 17, 2014 1:20 PM

To: Jason Boehlert

Cc: news@journalmfdhousing.com; ken@rishel.net; Rick Robinson

Subject: Re: MHI Housing Alert –  Senate Banking Committee Leaders Unveil GSE

Reform Plan – MHI Successfully Stakes out Ground for Manufactured Housing and

Personal Property Loans

Jason

You, in behalf of MHI did NOT answer the lead question in my email
correspondence dated 3/16/2014, to wit; “When  did MHI switch its’ primary
legislative focus from Dodd-Frank regulatory reform to GSE Reform?” You can
blather all you want about ‘A sampling of our most recent activities include
(but certainly not  limited to)’ to  cloud the issue – which I’m getting to –
but the fact remains, throughout the Fall of 2014 MHI had tunnel vision relative
to effecting Dodd-Frank regulatory reform.


The tenor of your sentence,”We do not comment on the activities or actions of
other national organizations – that is not our role. Nor do we believe it serves
the interests of the industry or our members to do so.” tells me you well
understand what I was referring to in the above-referenced email  message, i.e.
Quoting MHARR’s Press Release dated 3/16/2014:  “…MHARR today lauded the
inclusion of specific  MHARR-proposed language in the bi-partisan GSE housing
finance reform bill (S.1217)…(containing) “langaguage submitted to the Senate
Banking Committee in Septermber and October 2013….” There lies the crux of
this whole issue of giving credit where credit is due!


Being as new as you are to MHI’s staff, you can be forgiven for not knowing how
often in the past, MHARR and MHI have ‘worked together’ to effect federal
legislation, e.g. Manufactured Housing Impovement Act of 2000 is but one
example. And how both national advocacy bodies have, in the past, ‘commented
(appropriately &/or positively) on the activities or actions of other national
organization’ YES, that should be one of the rolls taken on by MHI even if it’s
not as commonplace today as it has been at times in the past.


Furthermore; speaking as a 35 year entrepreneur businessman in the manufactured
housing industry and land-lease-lifestyle community asset class, and 20+ year
direct, dues-paying member of MHI, I disagree with you! Interadvocacy body
cooperation/praise (as should have been in this instance!) does serve the
greater interests of the industry, and certainly its’ members!


I think it entirely appropriate, that sometime this week, MHI take steps to
right the  misunderstanding couched in the subtitle & text:HOUSING ALERT, i.e.
“…MHI Successfully Stakes out Ground for Manufactured Housing and Personal
Property Loans”, before someone else does it for you….


Need someone to do this  public relations magic for you? I can recommend
someone, if asked.

GFA
George Allen

—–Original Message—–

From: Jason Boehlert <jBoehlert@mfghome.org>

To: gfa7156 <gfa7156@aol.com>

Cc: news <news@journalmfdhousing.com>; ken <ken@rishel.net>; Rick Robinson <rrobinson@mfghome.org>; Richard Jennison <rjennison@mfghome.org>

Sent: Mon, Mar 17, 2014 3:05 pm

Subject: RE: MHI Housing Alert – Senate Banking Committee Leaders Unveil GSE Reform Plan – MHI Successfully Stakes out Ground for Manufactured Housing and Personal Property Loans

George,

I am sorry to hear you found my response to your original inquiry,
unsatisfactory. I believe I answered in an honest and thorough fashion. But, to
try and further clear things up:

1) MHI is a multifaceted trade association.  This requires us to multitask and
pursue multiple policy priorities at the same time. Our focus is not solely
limited to Dodd-Frank. It also includes GSE reform, HUD-MHCC issues, tax, energy
and environmental policies.  This does not require us to shift our focus, but to
add to it–and GSE reform has been a focus of MHI now for several years.

2) I do not work for MHARR. Therefore, I have no real knowledge of their
lobbying activities. As such, it would be wholly inappropriate for me to comment
on MHARR’s activities. Just as it would be wholly inappropriate for MHARR to
comment, with any real knowledge on MHI’s policy activities.

3) Had you been able to attend MHI’s legislative conference, you have
undoubtedly learned that MHI’s GSE reform activities have been substantial and
ongoing.  MHI’s GSE efforts have been significant and have unequivocally led to
this positive outcome.  I am sorry you are unable to see yesterday’s news as a
positive development for the entire industry.


However, if you feel additional clarification is needed please feel free to
contact MHI’s CEO Dick Jennison at 703.558.0678.

Jason

———-

From: <gfa7156@aol.com>

Date: March 17, 2014 at 3:47:48 PM EDT

To: <jBoehlert@mfghome.org>

Cc: <news@journalmfdhousing.com>, <ken@rishel.net>, <rrobinson@mfghome.org>

Subject: Re: MHI Housing Alert –  Senate Banking Committee Leaders Unveil GSE Reform Plan – MHI Successfully Stakes out Ground for Manufactured Housing and Personal Property Loans

Jason

You can dance around the issue all you want, but truth be told, GSE reform was not a primary focus for MHI during the last half of 2014. I am an MHI member read what little is sent my way these days.

Amazing. You & MHI claim no prior knowledge of the source of the language used in this bi-partisan GSE housing finance reform bill (S.1217), yet are bold to state: “MHI will continue in its’ role as the leading advocate for the manufactured housing industry to ensure that manufactured home finance opportunities are expended to the greatest extent possible in forthcoming housing finance reform measures.” By the way, in this sentence, did you intend for the word choice to be ‘expended’, rather than ‘expanded’ or some other appropriate non-dissipating word?

Of course I see yesterday’s developments to be of value to the entire HUD-Code manufactured housing industry. And I see MHI’s HOUSING ALERT, in the manner in which it was written, to be unequivocal grandstanding, when it’d have been highly appropriate, and much appreciated by ‘the entire HUD-Code manufactured housing industry’, if credit had been given where credit was truly do!

Thank You for fleshing out my story for this week, if nothing more newsworthy doesn’t come along.

GFA.

George Allen

—- end of emailed messages on this thread —-

An impartial reading of George Allen’s messages suggests is a either a lack of objective research into the ongoing efforts and engagement by MHI on the subject of GSE reform, or perhaps an effort to “agitate” (Allen’s word about himself) against MHI, and/or some other motivations.  Allen clearly implies his intent to write about this topic, which is certainly his right, but after reading this exchange, does an objective person believe that Allen will right about it in a fair and balanced fashion?  Or will Allen use this once more to “agitate” against MHI?

As noted previously,

  • a simple Google search revealed numerous links dating back several years regarding MHI engagement on the topic of GSE reform. Please see below.

  • A search on the MHProNews website proves the same point of MHI engagement on GSE reform that Jason’s replies state.  So does a review of MHI’s typically weekly reports, that go out to members like Allen, and as did the update briefings during their 2014 Winter Meeting and Legislative session that all referenced efforts by that national trade association on GSE reform.

Why Does Allen seek to Manufacture a new Controversy?

It should be noted that MHARR has indeed made GSE reform an issue they have pursued.

But what is lacking from MHARR’s President and CEO, Danny Ghorbani is the same credit to MHI’s efforts, that Allen allegedly seeks on Ghorbani’s behalf from MHI as a tip of the hat to MHARR.

Thus Allen and Ghorbani seem to want from MHI what they are unwilling to give themselves. On MHI’s part, Boehlert’s responses to Allen are polite and professional.

Prior to issuing this report, MHProNews reached out once more for comment to Messrs. Allen and Ghorbani. For those anxious to share their views to their select group of readers, they have opted not to state reasonable replies to our questions for the record to the largest professional audience in the industry.  Why are they ducking replies?

A copy of the questions sent to MHARR’s President and Vice-President are below, as are the questions sent to George Allen.

A download of the search results from Google on this date for “Manufactured Housing Institute” = “GSE Reform” produced the results shown in the attachment linked here, which also reflects search results found on MHProNews, both of which pre-date by months or years the MHARR initiative ballyhooed by Danny Ghorbani.

The initiatives in the Senate both MHARR and MHI reference provide reasons for hope for all in the industry.

By contrast, this apparent manufactured controversy detracts from what ought to be one of many joint steps forward by MHARR, MHI and state associations, who all should be working in concert on issues vital to the manufactured housing industry.

Inflammatory messages may help a pair of ‘leaders’ posture themselves as tough, but do such missives advance or harm the manufactured housing industry’s agenda, and the interests of their own followers?

Industry voices cited in the articles found in the links below question if Danny Ghorbani – with or without the aid of George Allen – can effectively deal with regulators and politicos, without major changes in his modus operandi…or will real leadership by MHARR’s CEO come from Ghorbani’s successor, should Ghorbani depart or retire? ##


Appendix

Questions provided to George Allen for response by MHProNews:

1) Will you publish the unedited reply from Jason this upcoming weekend on your blog, or will you continue on your allegedly pro-Danny Ghorbani/MHARR, anti-MHI public stance?

2) As a self-proclaimed MH Communities owner advocate, how do you defend Danny Ghorbani’s embrace of Ishbel Dickens and her anti-MHC owners organization, when Dickens has reportedly said in public that community owners are “the enemy…”?

3) You’ve described on your blog your activities in part as an “agitator. ”  You’ve described Danny Ghorbani as a “leader.” Yet in the past, you decried Ghorbani for very similar stands to his current one, and after your own analysis, described in the article and links from the post here,

http://MHProNews.com/blogs/tonykovach/mharr-after-danny-ghorbani-and-more-manufactured-housing-issues/

you concluded Danny was mistaken in his writing that you then cited.  Where you wrong then? How do you answer your own rejection of Danny’s views  then, what has he practically accomplished since then which has caused you to change your stance? How much has payments for ads or other money received from MHARR factories influenced  your new found admiration for Danny?

4) Why do you not show remarks opposing your views on your blog?

5) We’ve invited you and Danny to debate MH Industry related topics; why have you not done so?

6) As an industry commentator, did you know that GSE reform was on the MHI legislative agenda?

7) You are fine with asking questions, so why do you not provide the courtesy of replying to questions when you are asked?

Questions provided to Danny Ghorbani and M. Mark Weiss at MHARR

1) We’ve asked many times, and ask again, what are the achievements of your last last 5 years at MHARR?

2) Why is it necessary to undermine MHI to make yourself look better?

3) Specifically what did you do – apart from MHI – that makes this advancement in GSE Reform your sole victory?

4) And how is this bill – not yet a law – more of a victory than HR 1779 or S 1828?

Previous Reports, Posts and Articles on this or Related Topics

Some Related Story Links:

Downloads and Attachments:

Commentary on MHARR ad from a cross section of MHPros in the Industry are found here.

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