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Posts Tagged ‘Duty to Serve Underserved Markets’

MHARR to FHFA: Duty to Serve Requires Material and Expedited Support for MH Chattel Loans

February 10th, 2017 Comments off
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Credits: Embassy Suites, MHProNews, Wikipedia.

Washington, D.C., February 9, 2017 – The Manufactured Housing Association for Regulatory Reform (MHARR) tells MHProNews that, at a Federal Housing Finance Agency (FHFA) “listening session” in Washington, D.C. on February 8, 2017, President and CEO Mark Weiss reiterated and underscored previous remarks by MHARR representatives.

Weiss asserted that the Agency’s December 29, 2016 “Duty to Serve Underserved Markets” (DTS) rule and related “Evaluation Guidance” for DTS implementation plans do not and cannot comply with the essential legislative mandate of DTS and are, therefore, unacceptable.

MHARR says that the meeting opened with an appearance by FHFA Director Melvin Watt, who thanked DTS stakeholders for their participation and information provided regarding specific aspects of DTS’ implementation.

Watt also announced that the February 17, 2017 deadline for written responses to a detailed Request for Information (RFI) published by FHFA specifically concerning manufactured housing chattel loans, would be extended until March 21, 2017, which appeared to be a response to President Donald Trump’s regulatory “freeze” order, enacted on January 20, 2017.

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Credit: Scott Lewis, Creative Commons.

During the meeting, MHARR detailed the specific legal and policy bases for its position that any DTS implementation, in order to comply with the express directive of Congress as set forth in the Housing and economic Recovery Act of 2008 (HERA), must provide for a program of material and expedited Government Sponsored Enterprise (GSE) securitization and secondary market support for manufactured housing chattel loans, which comprise 80% or more of the entire manufactured housing market.

DTS was not an invitation for the GSEs to maintain the status quo for years or decades more,” said Weiss.

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M. Mark Weiss. Credit: MHProNews.

DTS does not stand for ‘Duty to Study.’

Weiss also commented on Director Watt’s actions.

As indicated by Director Watt’s action to extend the comment deadline for FHFA’s pending RFI, the January 20, 2017 regulatory ‘freeze’ order put in place by President Trump, by its express terms, also applies to the DTS final rule and subsequent Evaluation Guidance” said Weiss.

FHFA should use the additional time provided by this order to correct its approach to DTS and, with the additional information and input that it has received from stakeholders, revise both the final rule and its Evaluation Guidance to provide for an expedited path to material, mandatory GSE securitization and secondary market support for manufactured housing chattel loans.”

The full MHARR statement is available for Daily Business News readers here.

The full presentation from Weiss to the listening session is linked here. ##

(Image credits are as shown above.)

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RC Williams, for Daily Business News, MHProNews.

Submitted by RC Williams to the Daily Business News for MHProNews.

MHARR: FHFA Final Duty to Serve Rule Continues to Fail Manufactured Home Buyers

December 16th, 2016 Comments off
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Capitol Building credit, Wikipedia. MHARR, Mark Weiss image collage – MHProNews. MHARR logo is their intellectual property, and is shown here under fair use guidelines.

Washington, D.C. – The Manufactured Housing Association for Regulatory Reform (MHARR) reports to MHProNews that after review of the Federal Housing Finance Agency (FHFA) release of its final rule to implement the “Duty to Serve Underserved Markets” (DTS) provision of the Housing and Economic Recovery Act of 2008 (HERA), the organization sees limitations.

MHARR says that if the portions of this final rule addressing manufactured housing personal property (i.e. chattel) loans – which have been the continual focus of MHARR since the inception of the DTS rulemaking in 2010 — are any indication, the industry’s post-production sector may wish to carefully analyze all aspects of the final rule, which will continue to devastate the 80% of lower and moderate-income consumers who rely on chattel financing to purchase affordable manufactured homes.

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Credit: Neon Tommy.

The 241-page final rule – which MHARR suggests was released to another national association by FHFA pending formal publication in the Federal Register – would on its face nominally permit one or both of the Government Sponsored Enterprises (GSEs) to obtain DTS credit for manufactured housing chattel loans.

But MHARR says it does so under a veritable mountain of conditions, qualifications and limitations that are so restrictive, it is doubtful that the lower and moderate-income American consumers who rely on these loans will ever see any meaningful relief.  A MH lender privately told MHProNews that they didn’t expect the rule as it stands to do much for manufactured housing sellers and buyers.

For the full statement from MHARR, click here.

The Daily Business News covered the FHFA in a report linked hereMasthead commentary on this issue, is linked here. ##

(Image credits are as shown above.)

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RC Williams, for Daily Business News, MHProNews.

Submitted by RC Williams to the Daily Business News for MHProNews.