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What Congressional Representatives, Senators, and Industry Professionals Should Be Asking About Duty to Serve Manufactured Housing

June 18th, 2019 No comments

 

WhatCongressionalRepsSenatorsIndustryProfessionalsShouldBeAskingGSEDutyToServeManufacturedHousingMHProNews

There are several ways to understand people and organizations. One method, is to listen to what they say.

 

Another is to see how what they claim compares to what they actually do. 

Yet another is the investigator’s method, which is “follow the money.”

A classic variation on the above is the question: Cui Bono? Who benefits?

Toadies and lemmings will simply follow mindlessly, even if they are following a ‘leader’ over a cliff.

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MHInsider, George Allen, others are arguably the current examples of toadies to the industry’s powers that be.

The Manufactured Housing Association for Regulatory Reform (MHARR) has been pushing, prodding, and calling for action, not words by the Government Sponsored Enterprises (GSEs) of Fannie Mae and Freddie Mac with respect to their congressionally mandated Duty to Serve (DTS) manufactured housing.

By contrast, the Manufactured Housing Institute (MHI) has taken money from the GSEs to sponsor events that have failed to deliver DTS.

Who benefits from that, other than the largest corporate players that are trying to consolidate manufactured housing into ever fewer hands?

With that introduction, let’s dive into MHARR’s release, which follows below. That will be followed by some additional comments, links, insights, and information. 

MHARRlogoMHARRNewsHeaderMHProNews

MHARR REITERATES CALL FOR DTS INVESTIGATION

 

Washington, D.C., June 18, 2019 – The Manufactured Housing Association for Regulatory Reform (MHARR), in a June 13, 2019 communication to Fannie Mae Vice President Jonathan Lawless (copy attached), has reiterated its call for a congressional investigation into the failure of both Fannie Mae and Freddie Mac to implement the statutory Duty to Serve Underserved Markets (DTS) in relation to manufactured home personal property (or “chattel) loans.  Those loans, which provide consumers with the most affordable access to the nation’s most affordable non-subsidized homes, comprise nearly 80% of the manufactured consumer lending market.  Nearly 11 years after the enactment of DTS as part of the Housing and Economic Recovery Act of 2008 (HERA), however, neither Fannie Mae nor Freddie Mac have purchased any manufactured housing personal property loans pursuant to that mandate – which expressly includes such personal property loans – let alone provided the type of market significant securitization and secondary market support that Congress envisioned.  Indeed, even an extremely limited and highly restricted “pilot program” for such loans has yet to materialize after nearly two years of empty promises, and is referred to by Fannie Mae as only a “potential” pilot program. 

Instead of providing such crucial support for the largest single segment of the manufactured housing consumer lending market and mainstream, inherently affordable manufactured homes, as MHARR’s communication notes, both Fannie and Freddie have instead prioritized pilot programs for much higher-cost manufactured homes, as well as a supposed “new class” of manufactured homes with retail purchase prices as high as $220,000.00 – as contrasted with an average purchase of $71,900.00 for all types of existing, mainstream, HUD Code manufactured homes. Consequently, instead of expanding access to the industry’s most affordable mainstream homes, as DTS was designed to do, both Fannie and Freddie continue to discriminate against mainstream manufactured housing and mainstream manufactured housing purchasers, effectively forcing them into higher-interest loans offered by the finance subsidiaries of the industry’s largest corporate conglomerates, while stifling the recovery and market growth of the manufactured housing industry during a prolonged affordable housing crisis.  Indeed, this type of sustained institutional resistance to the full and proper implementation of DTS and the resulting ongoing discrimination against lower and moderate-income consumers of manufactured housing is, in substantial part, an outgrowth of the continuing failure of the industry’s post-production sector – dominated by the industry’s largest corporate conglomerates – to demand full compliance with DTS for manufactured housing.

Based, therefore, on the lack of any significant progress toward the market-significant implementation of DTS with respect to the vast bulk of the manufactured housing consumer financing market and apparent diversion of DTS activity into new, higher-cost types of hybrid manufactured homes, MHARR has called for a congressional investigation of Fannie Mae, Freddie Mac and their federal regulator, the Federal Housing Finance Agency (FHFA), with respect to unconscionable and unnecessary delays in the implementation of DTS for mainstream, HUD Code manufactured housing.

The Manufactured Housing Association for Regulatory Reform is a Washington, D.C.-based
national trade association representing the views and interests of independent producers of federally-regulated manufactured housing.

 

Manufactured Housing Association for Regulatory Reform (MHARR)

1331 Pennsylvania Ave N.W., Suite 512

Washington D.C. 20004

Phone: 202/783-4087

Fax: 202/783-4075

Email: MHARR@MHARRPUBLICATIONS.COM

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Think about what these MHI past and present members have said, and ask yourself, who side is MHI on?

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What Haney’s statement reflects is the lack of credibility and effectiveness of MHI in their claims.

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Marty Lavin advises, “Follow the Money” and “Pay More Attention to What People Do Than What They Say.” The GSEs are praising manufactured home quality, but then created a special class of manufactured homes, with key MHI member input, that is aimed at funneling that lending, per informed sources.

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Then, ask yourself, why hasn’t MHI done what MHARR is doing?

That’s tonight’s final installment of manufactured housing “Industry News, Tips, and Views Pros Can Use,” © here “We Provide, You Decide.” © ## (News, commentary, and analysis.) ##

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Related Reports:

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Manufactured Home Communities’ Dodd-Frank Moment Looms, Senator Elizabeth Warren Takes Aim at Several Manufactured Housing Institute Community Members

Dueling Statements, NAMHCO, MHI, MHARR, Weigh In On Controversial MH Bill, “George Allen Pawn Gambit”

 

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Washington Leak – Justice Department Prepares Major Antitrust Investigation

 

“Have…Giants…Stifled Competition,” Antitrust Battle Lines in D.C., plus Manufactured Home Market Updates

Shocking, True State of the Manufactured Housing Industry, plus Solutions for Profitable, Sustainable Growth – May 2019

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Photo of Commodore Homes model, MHARR logo, are provided under fair use guidelines. See article and letter to Secretary Carson, linked here. https://manufacturedhousingassociationregulatoryreform.org/mharr-calls-on-hud-secretary-to-end-discriminatory-and-exclusionary-zoning-of-hud-regulated-manufactured-homes/

 

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https://manufacturedhousingassociationregulatoryreform.org/time-to-investigate-fannie-and-freddies-mishandling-of-dts/

 

 

 

 

 

 

Investigating Fannie Mae, Freddie Mac Over Duty to Serve Manufactured Housing

June 13th, 2019 No comments

 

InvestigatingFannieMaeFreddieMacOverDutytoServeManufacturedHousingDailyBusinessNewsMHproNews

Facts are stubborn things.”

 

Assuming that the meaning of “new” hasn’t changed recently, “new” means “not done before.” And, if “new” still means “new,” then it also means, by definition, that there is no pre-existing loan performance data for that “new” class of home – because it’s … well … “new.” – Mark Weiss, J.D., President and CEO of the Manufactured Housing Association for Regulatory Reform (MHARR).

 

Wit is the soul of wisdom, goes an old maxim.

With that pull quote above from his full message below, Weiss exposes the apparent contradiction of providing Duty to Serve (DTS) lending for the Clayton Homes/Manufactured Housing Institute (MHI) backed ‘new class of homes.’

Attentive industry readers will recall that Fannie Mae and Freddie Mac have said that a ‘lack of data’ caused them to not dive deeply into manufactured home lending, especially on home only or ‘chattel’ personal property loans.  Yet they do have data on those loans. They also have the obvious example of several lender sustainably performing personal property loans.  That’s inferred performance.

By contrast, as Weiss said, the GSEs have no data whatsoever on this Clayton/MHI backed new class of homes.

An outraged MHI-only member producer told MHProNews in 2018 his disgust over how the GSEs snubbed the vast majority of manufactured housing by Fannie and Freddie with this phrase: “What are we chopped liver?”

 

“What Are We, Chopped Liver?” MHI Member December 2018 Reactions

 

Another MHI-only member producer told MHProNews about the same time that the new class of homes makes no sense. Per that source, the GSEs already did lending on par with conventional housing for modular homes.  Why establish this new class of HUD code manufactured homes, when modular housing already exists, and the same producers routinely do both? In a sense, it is arguably like doing nothing at all for manufactured housing, unless it is much the same as an on-frame modular unit.

 

Insider Insights from GSEs

The Daily Business News on MHProNews asked a consultant to a GSE, prior to the roll out of their ‘new class of homes,’ program the following.  Had the GSEs considered what the impact would be on the rest of manufactured housing? And if the ‘new class’ of homes was successful, what if it undermined confidence in the balance of all other manufactured housing?

The reply was stunning. Per that consultant, if a negative impact on other manufactured homes occurred, the GSE could always take that into consideration after a year or so of data was collected.

Rephrased, the consultant said the GSE was willing to risk undermining the value and confidence in all manufactured homes, in order to roll out the new Clayton/MHI backed project as they envisioned it.

Outrageous, but there it is.  Other consultants to GSEs told MHProNews equally stunning revelations.

 

But the focus of this report is the newest edition of MHARR ISSUES AND PERSPECTIVES.  It is being reproduced below in its entirety.  It will be followed by additional insights and commentary by MHProNews.

 

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“TIME TO INVESTIGATE FANNIE AND FREDDIE’S MISHANDLING OF DTS”

By Mark Weiss 

JUNE 2019

It’s been more than ten years since Congress enacted the Housing and Economic Recovery Act of 2008 (HERA) and its “Duty to Serve Underserved Markets” (DTS) mandate.  DTS directs both Fannie Mae and Freddie Mac to “develop loan products and flexible underwriting guidelines to facilitate a secondary market for mortgages on manufactured homes for very low, low and moderate-income families.” Insofar as it expressly authorizes programs for both real estate and personal property (chattel) manufactured housing consumer loans, DTS was – and always has been – aimed at increasing the availability (and lowering the cost) of purchase-money financing for mainstream, affordable manufactured homes by providing securitization support for lenders, which would lower their credit risk, while promoting greater market competition, which would also result in lower borrowing costs for consumers. That laudable objective, however, has not been achieved, and with the industry now in an eight-month sustained production decline, DTS remains a nearly empty shell, leaving the 80% of the manufactured housing consumer finance market that relies on personal property loans totally unserved, while scarce – and badly needed – DTS resources are diverted to programs that do nothing for mainstream manufactured housing consumers, but do benefit a handful of the industry’s largest corporate conglomerates. This “hijacking” of DTS, with the knowledge and support of both Fannie Mae and Freddie Mac, deserves a thorough investigation by Congress and full accountability for those involved.

 

Put simply, DTS was never designed to be a corporate welfare program for the industry’s largest conglomerates. But that is exactly what it’s becoming, as a result of its botched implementation by Fannie Mae and Freddie Mac (with a “wink and a nod” from their federal regulator, the Federal Housing Finance Agency – FHFA), and its diversion away from the mainstream, affordable manufactured homes produced by all HUD Code industry manufacturers, in favor of high-dollar, hybrid-type homes that are produced by only one or, at most, just a handful of manufacturers.  As usual, the winners in this fiasco (thus far) are certain well-heeled, well-connected industry conglomerates that play to the pre-existing prejudices of Fannie and Freddie, while the “losers” are the rest of the HUD Code industry and the millions of lower and moderate-income American families that could otherwise be helped by DTS to purchase and own a home of their own.

 

The factual analysis leading to these conclusions is, in actuality, simple, straightforward and fundamentally undisputed.  Start with a basic undisputed fact, as confirmed by federal government data.  That is — as shown by U.S. Census Bureau housing market data — that some 76% of all HUD Code manufactured housing placements in 2017 (the most recent year for which such data is available), were titled as personal property (i.e., chattel). While not necessarily representing a one hundred-percent direct correlation, this data effectively means that something close to three-quarters of the manufactured homes purchased in 2017 were financed as personal property, while only 17% of all manufactured homes that year were titled – and presumably purchased and financed – as real property. This division between personal property-based placement and financing on the one hand, and real estate-based placement and financing on the other, has remained relatively constant in recent years, moreover, with the proportion of personal property placements varying between 76% and 80%, while real estate placements varied between 13% and 17%.  Thus, there can be no actual or legitimate dispute that the vast bulk of the manufactured homes purchased by lower and moderate-income American families, are served by personal property-based chattel financing.

 

Nor is this – or should this — be a surprise to anyone.  While manufactured housing personal property loans generally carry a higher interest rate than real estate-based loans, due, in part, to the absence of land as security for the lender, personal property loans, using the home itself as the sole security for the lender, cost less overall than real estate loans which include the purchase cost of the land underlying the home.  As a result, personal property loans have tended to be favored by lower and moderate-income consumers, including consumers who might otherwise be unable to afford a home of their own. That is, with an average sales price of $48,300.00 without land (in 2017) a single-section manufactured home would cost far less to purchase and finance than either an average site-built home with land (with an average combined sales price of $384,900.00) or a single-section manufactured home with land, which, according to the same data, could add something on the order of $90,000.00 to the structural price of the home itself.  Consequently, even with higher borrowing costs for chattel loans (resulting from higher interest rates), such loans on HUD Code manufactured homes nevertheless represent – and have always represented – the most affordable route to homeownership for any American anywhere in the United States.

 

Given this basic, undisputed data, the most direct route to fulfilling the promise and mandate of DTS – i.e., putting more lower and moderate-income American families into homes that they can truly and legitimately afford – would be for Fannie Mae and Freddie Mac to provide market-significant securitization and secondary market support for the manufactured housing personal property consumer lending market, as MHARR has always maintained. This is where the vast majority of manufactured housing purchasers are, and where the vast majority of lower and moderate-income manufactured housing purchasers are. And, not to overstate the point, these are the very people that Fannie and Freddie should be serving and, in fact, were created to serve, and are directed to serve by their respective charters and authorizing legislation.

 

But Fannie Mae and Freddie Mac have no interest in serving the type of housing consumers served by mainstream manufactured housing. Thus, they have no interest in providing securitization and secondary market support for mainstream, chattel-financed manufactured housing.  If they did have such an interest, and had been serving the mainstream manufactured housing market all along, DTS would not have been necessary and would not have been enacted by Congress.  What need would there be for a remedy – such as DTS — if there was no problem to begin with?  Conversely, the fact that Congress felt the need to enact a remedy shows that there was, in fact, a problem with Fannie and Freddie’s treatment of manufactured housing consumers. But Fannie Mae and Freddie Mac, aided by FHFA and some within the industry, have worked overtime to circumvent that remedy, while they continue to discriminate against lower and moderate-income manufactured American families that seek to purchase a truly affordable, mainstream manufactured home. At the same time, Fannie and Freddie talk about support for the mainstream manufactured housing market while, in fact, doing no such thing.

 

How do we know this?  Again, “facts are stubborn things.”  To start with, the reality is that neither Fannie Mae nor Freddie Mac has yet to implement even a “pilot program” for manufactured home chattel loans, some 11 years after the enactment of DTS.  A May 23, 2019 letter from Fannie Mae Vice President Jonathon Lawless to MHARR thus refers only to a “potential” manufactured housing personal property “pilot” program. And forget any kind of market-significant support for the predominate type of manufactured home consumer lending in the United States. In fact, according to sources, Fannie and Freddie have yet to provide market support for any manufactured home consumer personal property loans under DTS – a point effectively confirmed by Mr. Lawless, whose May 2019 letter states that Fannie Mae’s DTS Plan “has never called for [the] immediate purchase and securitization of these [personal property] loans.”

 

And what are Fannie Mae and Freddie Mac doing instead?  Rather than providing the type of market support that is desperately needed to expand the availability and affordability of mainstream manufactured homes for lower and moderate-income purchasers – what they should be doing under DTS – Fannie and Freddie instead, are offering support for the types of “manufactured homes” that they want to see and promote; not mainstream, affordable, HUD Code manufactured homes, but “manufactured homes” that are more like the far more costly site-built homes that Fannie and Freddie are accustomed to dealing with. Thus, in a January 14, 2019 article entitled “Delivering on Our Affordable Housing Mission Under Duty to Serve” (and there are many more such examples), Fannie Mae Executive Vice President Jeffrey Hayward refers to “manufactured homes” constructed in accordance with Fannie’s “MH Advantage” program – for manufactured homes titled as real estate (not chattel) – as being “similar to site-built homes.”  And, of course, this is – and remains – Fannie and Freddie’s central criterion in providing support for “manufactured homes” – i.e., they cannot be mainstream (and therefore affordable) manufactured homes but, instead, must be “similar to [the] site-built homes” that Fannie and Freddie are used to dealing with, and thus are within their pre-existing “comfort zone.”

 

It’s the same thing with the so-called “new class” of manufactured homes.  These homes are described (and specified) as being more like site-built homes – or a hybrid between site-built homes and manufactured homes.  As a result, they are projected to cost significantly more than an “average” mainstream manufactured home – up to approximately $220,000.00 as compared with an “average” (2017) price of $71,900.00 for all mainstream manufactured homes (i.e., both single and multi-section) — and are simply not the type of affordable, non-subsidized affordable housing resource that is provided by mainstream manufactured housing; meaning, again, that they would appeal – and be marketed to – the more “upscale” consumers that Fannie and Freddie would prefer to deal with.

 

And just as long as we’re on the subject, what type of loan performance data exits to support the creation of a special program for this supposed “new class” of manufactured home (or “MH Advantage” homes for that matter)?  For more than a decade, Fannie and Freddie have refused to provide any type of DTS support for mainstream manufactured housing personal property loans, citing a lack of “performance data” to justify entry into that market. So, if the availability of “performance data” is thus a prerequisite for market support from Fannie and Freddie under DTS, what type of “performance data” do Fannie or Freddie have for an entirely “new class” of home?

 

Assuming that the meaning of “new” hasn’t changed recently, “new” means “not done before.” And, if “new” still means “new,” then it also means, by definition, that there is no pre-existing loan performance data for that “new” class of home – because it’s … well … “new.” So, for the 80% of the existing, mainstream manufactured housing market financed through chattel loans, no performance data means no DTS support. It means not even a measly “pilot program” after 11 years. But for a “new” class of higher-cost home, being pursued by just a few of the industry’s largest conglomerates (if that many), no performance data means a ticket to instant Fannie and Freddie support – even though there is not one word about a “new class” of manufactured homes or a pilot program for a “new class” of manufactured homes in the DTS implementation plans filed by Fannie and Freddie and approved by FHFA in 2018.  And all of this comes to you courtesy of the same people who nearly crashed the world economy by backstopping trillions of dollars in “subprime” loans on homes that borrowers could not legitimately afford.

 

The reality is that DTS is in the process of being “hijacked” by special interests. It is being diverted from its primary, essential and crucial mission with regard to manufactured housing – to expand the availability of consumer loans for mainstream manufactured housing; to bring more lenders into the market; and to lower the (interest) cost of mainstream manufactured home consumer loans through increased competition and risk reduction for lenders. Fannie and Freddie’s treatment and botched implementation of DTS is an ongoing farce for the industry and an ongoing tragedy for lower and moderate-income Americans who simply wish to purchase a home of their own, but continue to be subjected to flat-out discrimination, in open defiance of Congress and with a knowing, and apparently intentional pass from FHFA. The time has come, therefore, for Congress to re-involve itself in this matter, to conduct a thorough and probing investigation of DTS with respect to manufactured housing, and see to it that the DTS directive is enforced and implemented now, not “honored” in the breach.

 

Mark Weiss

 

MHARR is a Washington, D.C.-based national trade association representing the views
and interests of independent producers of federally-regulated manufactured housing.

 

— ## —

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Disclosure

Stating the obvious, let’s nevertheless note as a disclosure that MHARR is a banner advertiser, thus a sponsor of this publication. That noted, Berkshire Hathaway subsidiaries – Clayton Homes, 21st Mortgage Corporation – and the Manufactured Housing Institute (MHI) were also banner advertisers/sponsors of this site – which is the industry’s largest and most read manufactured home trade media by far. Our fact-checks of MHI, et al began while they were advertisers. Our fact-checks began years before MHARR became a sponsor.  Therefore, we have a clearly established record of covering matters as we see them.

It must also be noted that while we were doing such fact-checks and analysis, that MHI’s elected and staff leaders were publicly praising MHProNews.

 

 

 

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Our publisher – L. A. ‘Tony’ Kovach – has also stated several times in ‘digital print’ that in hindsight, he now sees the disconnects.  For example, there was Warren Buffett’s very public support of candidates who signed into law and worked to protect from any changes the Dodd-Frank legislation that gave birth to the Consumer Financial Protection Bureau (CFPB). Meanwhile, Clayton Homes, 21st Mortgage, other Berkshire Hathaway brands, and MHI all spent years and millions of dollars ‘opposing,’ lobbying, and fighting to modify. A detailed review of that ‘Rope-a-Dope’ is linked here. That fact-check and analysis includes this following stunning admission by a former MHI SVP who could not have been clearer. The years of efforts that lied ahead were a waste of time and money.

 

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Satirical cartoons can illustrate meaningful points.

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The Common Threads?

The common thread between DTS and the never-enacted Preserving Access to Manufactured Housing Act are access to financing. Our publisher stressed that the principle behind Preserving Access – or DTS – are fine. In the case of Preserving Access, while it was a ‘good idea,’ it was also all but guaranteed to fail. There was no practical logic in pursuing it.

What has been occurring with DTS is similar. So Weiss’ points are timely.

An MHI-only member connected source that’s worked with the GSEs has told MHProNews that part of what caused Fannie and Freddie from not implementing DTS in the aftermath of the passage of the Housing and Economic Recovery Act (HERA) 2008 was the relatively poor performance of 21st Mortgage Cop and Vanderbilt Mortgage and Finance (VMF) lending.

Now, given the mainstream housing mortgage/credit meltdown, that ‘relatively poor’ has to be considered in the broader context.  After all, lending did return to conventional housing, despite the scandals that occurred.  Manufactured homes had negligible impact on the 2008 housing/mortgage crisis that trigged the so-called ‘great recession’ that rippled through the world’s economy.

As a former MHI connected executive has said, manufactured home lending and past losses were a “pimple on an elephant’s ass” compared to what happened with conventional housing.

 

“An Elephant Ass,” Understanding GSEs, Duty to Serve, Manufactured Home Lending

 

Let’s recall that the 2008 housing/mortgage crisis was not the first such event.  The S&L crisis was smaller by comparison, but had an estimated $160 billion finance impact.

 

SavingsLoansCrisisWikiDailyBusinessNewsMHproNews

 

Within that context, what’s noteworthy is that per various sources, Berkshire owned lenders de facto helped derail the use of DTS early after its passage and were a source of an excusing DTS now on virtually all but this new class of homes.

21st, Clayton, and Warren Buffett de facto revealed their responsibility for their harmful impact on manufactured home lending which caused thousands of retailers and some producers to go out of business.

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In a series of direct quotes in context, a document from 21st Mortgage signed by Tim Williams, and video recorded comments by Kevin Clayton, these all line up to demonstrate how independent retailers, communities, and producers – among others – where purportedly harmed by action that could be deemed an antitrust violation. Why hasn’t Allen told his readers how that cost them money? https://www.manufacturedhomelivingnews.com/bridging-gap-affordable-housing-solution-yields-higher-pay-more-wealth-but-corrupt-rigged-billionaires-moat-is-barrier/

 

That in turn also arguably kept lending from flowing back into the manufactured housing space.

 

DTS Manufactured Home Lending Committee Member Says MHI in “Unholy Alliance” to Divert Needed GSE Support Away from Manufactured Housing

 

The aftermath and outcomes were many. These incidents contributed to the tidal shift that hit not only manufactured home retailers, but also communities, occupancy, and thus their values were impaired too.

 

Manufactured Home Community Case Study, UMH Properties, Lessons for Independent Community Owners, Investors

 

There is also an element of self-fulfilling prophecy in this matter. A lack of lending naturally harms resale values of manufactured homes, much like it did with conventional housing during the housing/mortgage crisis.

Furthermore, as was reported last year, it was the Federal Housing Finance Agency (FHFA) that said that manufactured homes demonstrably appreciated in value. Given the various ways that lending to manufactured homes have purportedly been artificially limited, that factoid is a pleasant surprise.

It should be noted that virtually all of what Weiss has recounted occurred prior to the Mark Calabria becoming Director of the FHFA.

 

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In a previous comment to MHProNews, Weiss made the previous statements above and below about Duty to Serve (DTS).

 

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Additional points that bears mention is that the GSEs have been sponsoring MHI events. How is that not a conflict of interest?

 

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Marty Lavin advises, “Follow the Money” and “Pay More Attention to What People Do Than What They Say.” The GSEs are praising manufactured home quality, but then worked with Clayton Homes and MHI to create a so-called ‘new class’ of manufactured homes, per sources.

 

Furthermore, well prior the Calabria era beginning and before the new Congress being seated in 2019, Jeb Hensarling pointed to what he felt was improper lobbying by GSEs. One of several possible references to that is linked via the text-image box below.

 

Update on Fannie Mae Lobbying, and Manufactured Housing Controversy

 

 

Conclusions

There is a quilt-work of items that are causing the slowdown and underperformance of manufactured housing. Financing must rank high on that list, for the reasons noted herein.

But at the core of these concerns ought to be the common threads.

  • Clayton Homes, 21st Mortgage, Vanderbilt Mortgage and Finance, and Berkshire Hathaway have their finger prints on these matters.
  • Clayton and their related Berkshire lenders has been spotlighted by several Democratic lawmakers, including 2020 presidential hopefuls.

 

Senate Democrats – Including 2020 Presidential Contenders – Ask CFPB Protect Consumers Against Predatory Lenders — Point Finger at Clayton Homes, Berkshire Hathaway Lending

 

  • The Manufactured Housing Institute (MHI) held closed door meetings with the GSEs, that none of the parties involved have released meeting minutes on.  They should be part of any Congressional or other investigation.
  • The Seattle Times, and Clayton’s hometown local news media – besides MHProNews – has reported on numerous federal investigations relative to Clayton that purported involve MHI connections.

 

 

 

One of the posted comments on the video above, from ‘Tobz4uhuni ItsMyName’ posted this, with typos in the original:

Clayton aka Vanderbilt is a horrible place. I have been in mine since 07. They placed it on the wrong land and it sets off by 3 acres. They know they did this and refuses to move it and correct the problem. They also have been offered a deed to the piece of land where it sits providing they quit claim the other piece of land that sits 3 acrea off and they refuse to move. Yet these unethical people, predators, illegal subhumans expect for me to pay for this mobile home when it isnt attached to the acre its suppose to. It sits on someone elses land and he will be moving it soon bc he is building a home where the mobile home sits. Clayton can make it right, but refuses. Plus they sell someone whose credit scores are 500 and 525 mobile homes with a price tag of 63k, an interest rate of 10.5% and make only 9 dollars an hr. Make complaints with your attorney generals office, the state of Tennessees attorneys office and the consumer protection bureaus office. These people need to be stopped.”

These may well rise to the level that merit Congressional investigation, but also Department of Justice (DoJ) investigation.  In a recent statement, DoJ’s top antirust person made statements that if applied to Clayton et al could be seen as a warning sign. See the link here, and the related reports, further below.

RememberThisQuoteIrPrettyPicturesMHIndustryWillOnlyAchieveItsGoalsByResovingItsCoreIssuesLATonyKovachMHProNews

That’s today’s second episode of News Through the Lens of Manufactured Homes, and Factory-Built Housing,” © where “We Provide, You Decide.” © ## (News, analysis, and commentary.)

 

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Shocking, True State of the Manufactured Housing Industry, plus Solutions for Profitable, Sustainable Growth – May 2019

Secretary Ben Carson’s, Julian Castro’s Manufactured Housing, “Trailer,” “Mobile Home” Revelations, 2020 Battles Ahead

 

 

 

 

 

Secretary Ben Carson’s, Julian Castro’s Manufactured Housing, “Trailer,” “Mobile Home” Revelations, 2020 Battles Ahead

June 8th, 2019 Comments off

 

HUDSecretaryBenCarsonJulianCastroManufacturedHousingTrailerHouseMobileHomeRevelations2020BattlesAheadMHProNews

Department of Housing and Urban Development (HUD) Secretary Ben Carson, M.D., has demonstrably done much since taking his oath of office to advance a proper understanding of manufactured homes.

 

In fairness, his predecessor Julian Castro, made a video that praised manufactured housing too.

 

 

While the next video interview with then Secretary Castro unfavorably used “trailer” terminology, the former mayor of San Antonio and current 2020 Democratic presidential nomination hopeful, nevertheless stressed the need for manufactured homes as an affordable housing option. Castro also stressed the need for resident protections, years before Last Week Tonight with Joy Oliver’s viral video misnamed “Mobile Homes” did.

 

 

Thus, videos and interviews by Dr. Carson as a HUD Secretary highlighting manufactured homes are not totally unique. There have been years of bipartisan efforts involving manufactured homes in this decade and previous ones too.

 

 

That is as it should be as affordable housing has been and remains a crisis.

 

 

It is also arguably part of HUD’s mandate that such pro-manufactured home statements and efforts fulfill.

Manufactured housing is the private sector solution to this problem, as Secretary Carson has underscored in various ways since taking on his new role. The evidence suggests he has been doing more to promote manufactured homes and other private sector innovative housing options than any HUD Secretary in the 21st century.

 

 

One can say he has built upon the foundation laid by his predecessor.  Indeed, the two echo the case made by a bipartisan group of Minnesota lawmakers who cited the facts that point to manufactured homes being an important part of the solution for the affordable housing crisis.  The recent event on the National Mall, reflected in 2 of the videos above, was positive and could be potentially useful for the industry to clarify outdated misconceptions.

 

 

But all of that begs several questions for the inquiring mind. For example:

How is it that during an ongoing affordable housing crisis, given all the useful facts and evidence, that the market share of manufactured homes has declined in the overall percentage of new housing starts?

 

AveragePriceExisitngNewMobileHomeManufacturdHomeByYearSince1960GraphicNARManufacturedHomeDataResearchMHProNews

Insightful data, per NAR. From the July 2018 update of the Realtor University report available from this link here as a download, along with other third party studies on manufactured homes.

3ErasMobileHomesManufacturedHomesManufacturedHousingImprovementActEraSkylineChampionShipmentProductionGraphicMHProNews

In 1998, manufactured homes (MH) outsold RVs by some 3 to 2. In 2017, RVs outsold MHs by some 5 to 1. RVs recovered far more quickly from 2008. The facts raise questions. One, is the effectiveness of MHI as the post-production or ‘umbrella’ association in the country. The other question is more sobering. Has Buffett-Berkshire “Moat” strategies kept manufactured home production at historically low levels to allow a few big boy brands to consolidate others at a discounted ‘value’ by MHI insiders? Note that even an exiting MHI president took thinly veiled parting shots at his own association, see that, linked here

 

How is it that the use of the pejorative and inaccurate term “trailer” has grown in recent years, instead of diminished?

 

ManufacturedHomeDescriptionForemostInsuranceGroupResearchDailyBusinessNewsMHLivingNews

NFPAManufacturedHomeIsNotaMotorHomeOrTrailerAlthoughItisOftenCalledMobileHomeItIsNotThatEitherNFPADailyBusinessNewsMHProNews

This is not a perfect definition by the NFPA, but it is clarifying and accurate.

 

What most think of as “mobile homes” has not been built in the U.S. since June 15, 1976. It was on that date, now some 43 years ago, that the mobile home era ended and the federally regulated HUD Code “manufactured home” era dawned.  These are construction, safety, and energy standard differences, not just marketing nomenclature.

Terminology2HarvardFreddieMacNeighborworksManufacturedHomeDefintionMobileHomeTraileModularPanelizedDailyBusinessNewsMHProNews432

TerminologyMattersBecausetheTerminologyDescribestheConstructionStandardsHomeBuiltToSteveDukeLMHAaMHLivingNewsMHProNewsBiggerPocketsSunshineHomesRedBayAL

 

Mobile homes served a useful and important purpose prior to the HUD Code. Millions of pre-HUD code mobile homes are still serving as some of the nation’s most affordable homes, often with updates added since they were first built.

 

UltimateManufacturedHomeHousingInfographicNotMobileHomeTrailerHouseFactoryBuiltHomeIndustryDailyBusienssNewsMHProNews-600

Recent post-Oklahoma, Alabama tornado fact-check, videos, and related reports, linked here.

 

Indeed, the HUD Code manufactured home industry has over two decades or positive, third-party research to back up the claim that it is the most proven form of permanent affordable housing used in the United States today.

 

 

Which again begs questions. With so much useful data and evidence, why has manufactured housing been the solution for the affordable housing crisis that is hiding in plain sight?

 

TerryDecioSkylineChampionHomesPhotoQuoteImTiredofManufacturedHousingbeingBestKeptSecretReadyHelpHouseAmericaDailyBusinessNewsMHProNews

 

Earlier this year, the Manufactured Housing Association for Regulatory Reform’s (MHARR) Mark Weiss, JD, used an interesting phrase to capture what he and his colleagues believe is an “Illusion of Motion” at the Manufactured Housing Institute (MHI). It was a new way to illustrate prior claims that MHI has been failing the industry’s post-production efforts.

The “Illusion of Motion” built upon a research study from MHARR President and CEO Weiss in November of 2017. That MHARR study demonstrated a need for a new body to represent communities, retailers, lenders, and others who are “post-production” operations. Producers, in this context, are those who build HUD Code manufactured homes, which MHARR itself is, as they state that they represents the interests of independent producers of HUD Code manufactured homes.

Post-production topics are those issues that arise after a home leaves the factory.

Those post-production issues would include, but are not be limited to, zoning, placement, and financing issues.

Is MHARR alone in such concerns? Hardly.

Some manufactured home community associations broke from MHI, saying something similar. Neal Haney, who in 2018 co-founded the National Association of Manufactured Housing Community Owners (NAMHCO), said before their trade group was formalized why they broke from MHI in the first place.

 

NealTHaneyNAMHCOWhyBreakawayfromManfuacturedHousingInstituteMHI

 

Publicly traded UMH President and CEO and MHI member said the following.

 

SamLandyQuotePeopleNeedQualityHomeReasonablePriceWeMHIndustryProvideThatOnlyEconomicDistortionsCausedByGovtMadeOurIndustry

 

Another MHI community sector member was more specific, pointing to financing related issues.

 

KennyLipschutzHomeFirstCertifiedCommunitiesMHINCCmemberPuzzlesWhyMHIDailyBusinessNewsMHProNews

FrankRolfeMHIChairmanNathanSmithSSKCommunitiesHypocrisyQuote-MHProNews

Numerous third party media reports underscored Rolfe’s claim. See several of those mainstream media video reports, linked here.

 

But to Landy’s and Lipshutz’s points, wasn’t it Warren Buffett, Chairman of Berkshire Hathaway, which includes MHI dominating forces such as Clayton Homes, 21st Mortgage Corporation, and Vanderbilt Mortgage and Finance, that supported presidential candidates that in turn backed the legislation that was the source of complaints like those cited above? 

Or why hasn’t Berkshire Hathaway used their dozens of BH Media Group and other media resources to clear up the mysteries about manufactured homes?

 

WarrenBuffettBillClintonHillaryClintonBarackObamaKevinClaytonNathanSmithPhotosDailyBusinessNewsMHproNews600

 

Or ponder what MHI member Frank Rolfe and Dave Reynolds of controversial RV Horizons – said this as part of a longer statement issued on June 1, 2019.

 

FrankRolfeDaveReynoldsRVHorizonsMobileHomeUQuoteSlammingManufacturedHousingInstituteMHI

 

 

Mysterious Disconnects and Apparent Ineffectiveness, Why?

This pro-industry trade publication, our sister operations such as consulting, and our the general public focused Manufactured Home Living News (MHLivingNews) were MHI members for some 7 years. MHProNews and MHLivingNews were praised by several MHI elected and staff leaders, as what follows demonstrates.

 

TimWilliamsMHProNewsMHLivingNewsGoodCommunicationsResourcesILogonLatestNewsBigAssetExplainWhyIndustryVoices-768x339

Part of several messages for publication by Tim Williams that praised the pro-industry work of MHProNews, and our sister site. We at times take a light-hearted, or even satirical approach, to illustrate the issues. See an example of that in the video, below.

 

 

HowardWalkerJDELSViceChairmanPhotoManufacturedHouisngInstituteMHIExecuitiveCommitteeBoardMemberDailyBUisnessNewsMHProNews

The words of the late Howard Walker, ELS Vice Chairman, shared for publication with MHProNews.

Disclosures

By way of disclosure, ours is a for-profit organization, that has been supported at various times by MHARR, MHI, and companies which are members of each trade group.  Our editorial stance is demonstrably based upon a simple premise. That the manufactured housing industry is much needed, misunderstood, and should be performing far better during an affordable housing crisis.

We’ve supported and led the way on educational initiatives, such as fact, evidence, and third-party commentary focused MHLivingNews. As pro-consumer, pro-free enterprise trade media, and as industry experts/consultants/service providers, we have long believed that manufactured homes are a nonpartisan or bipartisan solution for the need for affordable housing.

The homes our industry produces routinely serve the nation with no-taxpayer subsidies.

At various times, we’ve questioned the efforts of a variety of trade groups, based upon the evidence known at that time. So those MHI surrogates that allege differently are demonstrably mistaken. It’s our follow-the-evidence, facts, common sense, patterns, and the money-trail that has made and kept us the runaway most-read trade media in our industry’s history.  The top people and management in MHI companies, MHARR member firms, or among non-association aligned companies of all sizes have told us that they are regular readers.

 

BarryColeMHInsuranceRVMHHallofFameCongratsManufacturedHomeIndustryMHProNews

 

That’s not said to brag, but rather to clarify that we’re not crackpots on the sidelines spouting nonsensical conspiracy theories. We cite sources accurately, provide evidence, follow-the-money trail, and give those we question in our fact-checks the opportunity to respond. As recently as a few days ago, MHI’s and Berkshire’s manufactured home corporate leaders were given an opportunity to explain concerns like those noted herein.

Their response?  No comment.

Given that MHI leaders themselves have praised us publicly, that begs more questions.

Why on various occasions have their general counsel, or outside attorneys for MHI, threatened us in writing over evidence-based reports?  Note that after several years of that, they’ve never taken legal action; perhaps wisely so. Because how would they justify a suit against an operation that they’ve praised? Or how do they attack a trade media source whose goal is to see the industry grow to its potential?  Wouldn’t a suit open them up to a counter-suit, that could lead via discovery to them being forced to disclose information that they’ve withheld when requested in recent years?

The evidence suggests that the powers that be in MHVille praised us up until our fact-checks and analysis apparently made them too uncomfortable.  But instead of disproving or explaining away the concerns raised here, they stopped responding, and used other tactics instead.  Besides legal and other threats, they apparently lined up surrogates.  One of them is the one that follows.

 

WeveGotAProblemGeorgeFAllenQuoteCommunityInvestorEducateMHCSECOMobileHomeParkManufacturedHomesMHProNews

To see more disconnects between Allen and his flip-flops, then and now, click here and here.

ManufacturedHousingIndustryMonopoly-Oligarchy-GeorgeAllen-PostedDailyBusinessNews

The word heard is that MHI-connected leaders made a bargain with Allen to get him to praise them and attempt to diminish our trade media. Allen has called for a boycott of this publication, in writing.  Among the problems with that approach has been that Allen himself has blasted MHI, Clayton Homes, and others for the same kinds of concerns that we or MHARR, among others, have raised. To our knowledge, Allen has never explained his flip-flops on his blog or other musings.  By contrast, Allen’s record of criticism of those he now embraces is evidenced by the pull quotes as shown.  Rephrased, Allen makes a poor surrogate, as he’s made similar allegations himself, prior to his recent flip-flop.

GeorgeFAllenCommunityInvestorEducateMHCSECOcoba7MonopolyConsolidationClaytonHomes21stMortgageBerkshireHathawayQuotesManufacturedHomesCommunitiesMHproNews

Like MHARR – indeed, citing MHARR, Allen called for a new post-production association. Oddly, Allen more recently has attacked MHARR, whose position has been consistent, while Allen’s has arguably vacillated based upon MHI’s support, or not. But Allen is but one of many who have made allegations of monopolistic practices in manufactured housing. 

DougRyanAmericanBankerManufacturedHousingMonopoly-postedDailyBusinessNewsManufacturedHousingIndustryProNews-575x237

While MHI’s SVP Lesli Gooch has denied the charge, Doug Ryan at CFED (renamed Prosperity Now), and long time MHI member, George Allen, are among those who’ve raised the issue of monopolistic practices by MHI. 

AustinFrerickOpenMarketsAntiTrustAntiMonopolyClaytonHomesWarrenBuffettPredatoryLenderMinoritiesMoreDailyBusinessNewsManufacuredHousingIndustryMHProNews

Austin Frerick with the Open Markets nonprofit is among a range of writers that span the left-right media divide which have criticized Buffett’s tactics as monopolistic.

HowClaytonHomesMakesMoneyAustinFrerickTwitterOpenMarketsDailyBusinessNewsManufacturedHousingIndustryMHProNews

 

BloombergShipmentProductionDataManufacturedHousingMHProNews2019-05-16_1057

Let’s note here that success in an industry – honestly earned – is not what we’re called out. Antitrust laws are not designed to punish success, as a former DOJ antitrust professional recently said. However, various kinds of bad behavior may be violations of antitrust or other laws. That’s what our concerns are aimed at. Evidence and allegations of violations of the law.

 

Does Monopolistic Machinations Explain Why MHI Is Ineffective? Or Why Manufactured Housing Has Retreated Since Berkshire Bought Clayton Homes?

Which begs perhaps the most salient points at this time in the wake of what is properly understood as a positive week by Secretary Carson’s Innovative Housing Showcase.

For all of the positive and apt points that Dr. Carson has raised, why has he never mentioned “enhanced preemption?”

–      Is it possible that HUD staff – that certainly must be aware of that provision of the Manufactured Housing Improvement Act of 2000 (MHIA 2000) – has not told him about the enhanced preemption of manufactured housing passed by Congress in a bipartisan way, which was signed into law by President Bill Clinton?

–      Is it possible that MHARR’s letter addressed to Secretary Carson on enhanced preemption was not provided to him?

–      Is it possible that MHI has not raised and pressed this issue of enhanced preemption, in their several meetings with HUD staff?

Noting that MHARR and MHProNews are among those who’ve promoted enhanced preemption in digital print for years, more on those questions later.

But for now, let’s point to our recent report on that in the linked text-image box below, and then press on to what is shaping up as a serious issue in the approaching 2020 presidential and congressional campaigns.

 

Manufactured Housing Professionals, HUD Secretary Ben Carson, Must Promote These Two Words

 

 

Senator Elizabeth Warren, Other 2020 Democratic Candidates, Affordable Housing, and Manufactured Homes

There is an affordable housing crisis in this country,” says Senator Elizabeth Warren in the video below. “That’s why we are here. A safe, stable, affordable home is the foundation for almost everything else in our lives.”

That statement by Senator Warren is every bit as accurate as the ones by HUD Secretary Carson who has said similarly, in his own words.

Note that at the time that Senator Warren made this comment in the MHAction video below, MHProNews was not yet aware of the financial connections between Warren Buffett, Chairman of Berkshire Hathaway, which owns Clayton Homes, 21st Mortgage Corporation, Vanderbilt Mortgage and Finance (VMF), and numerous other interests that are directly engaged in the manufactured housing industry. Buffett bucks fund the Tides nonprofit, which in turn funds MHAction. Restated, it isn’t just progressive billionaire icon George Soros who is supporting some of these groups.  Warren Buffett has been too. Buffett and Berkshire have arguably been funding both sides of the fight over key issues in manufactured housing.

 

 

That noted, Senator Warren – sometimes in concert with congressional representatives – has fired off several letters to firms that routinely have ties to the Manufactured Housing Institute (MHI). Copies of those letters can be found as a download in the report linked below.

 

Manufactured Home Communities’ Dodd-Frank Moment Looms, Senator Elizabeth Warren Takes Aim at Several Manufactured Housing Institute Community Members

 

Warren and other 2020 Democratic hopefuls have raised the issue of Clayton Homes, and their fellow Berkshire Hathaway owned manufactured housing industry lenders, in a letter to the CFPB. See that in the report linked from the text-image graphic below.

 

Senate Democrats – Including 2020 Presidential Contenders – Ask CFPB Protect Consumers Against Predatory Lenders — Point Finger at Clayton Homes, Berkshire Hathaway Lending

 

Anti-monopolistic actions are taking a more important role on the national stage, as the Department of Justice (DoJ) and the Federal Trade Commission (FTC) have reportedly launched antitrust probes. Clayton has been accused of racism by Democratic leaders too.

 

President Donald J. Trump, a variety of Democratic and Republican leaders, have raised several concerns over consolidation, tipping the scales of free speech online, antitrust, and monopolistic behavior in the last 2 years.

 

Washington Leak – Justice Department Prepares Major Antitrust Investigation

 

While there is known to be such probes regarding the FAANG stocks, and so-called Big Tech, our sources tell us that Berkshire Hathaway’s activities has also been brought to DoJ’s antitrust division’s attention.

The Seattle Times similarly reported in 2018 that several federal investigations are underway in Washington involving Clayton and their related lenders.  Knoxville, TN metro based Clayton and their related lending units were spotlighted by their hometown media, in the May 22, 2018 video report below.  So there is smoke, does it suggest a fire?

 


 

Several Mainstream Media Reports cited Concerns Over Monopolistic Practices, and Often Name Buffett, Berkshire, and Clayton Homes

·        The New York Times had an interesting article on the historic trends, and named several industries being monopolized.

·        The Atlantic, without specifying how the monopolization was being accomplished, noted that the independent retailers in manufactured housing were being rapidly eliminated/consolidated, that report is linked here.

·        GuruFocus said “Warren Buffett Can’t Escape Unethical Strategic Moats,” their specific points are linked here.

·        The Nation called it “The Dirty Secret Behind Warren Buffett’s Billions…” and specifies Clayton Homes among those using the strategic moat in ‘dirty’ ways.

·        The Jacksonville Florida Times Union summarized the connection between the John Oliver viral hit video dubbed “Mobile Homes,” MHI, Clayton Homes, and their related lenders. That op-ed was first fact-checked by an editor, before it was published not only in the one newspaper it was submitted, but at least in 5 Florida newspapers.

While these and other mainstream media sources that span the left-right spectrum have pointed to ethical and other concerns with respect to Warren Buffett’s ‘strategic Moat,’ it is Manufactured Home Living News and this platform have to date documented specific examples. Attorneys which have reviewed the report linked below say is compelling evidence of antitrust violations by MHI’s most prominent member, Clayton Homes and their affiliated lender, 21st Mortgage.

 

SmokingGunEvidenceOfAntiTrustMonopolisticCollusionMoatClaytonHomesKevinClayton21stMortgageTimWilliamsWarrenBuffettMHLivingNewsMHProNews

In a series of direct quotes in context, one of two such documents from 21st Mortgage signed by Tim Williams, and video recorded comments by Kevin Clayton, these all line up to demonstrate how independent retailers, communities, and producers – among others – where purportedly harmed by action that could be deemed an antitrust violation. https://www.manufacturedhomelivingnews.com/bridging-gap-affordable-housing-solution-yields-higher-pay-more-wealth-but-corrupt-rigged-billionaires-moat-is-barrier/

 

Finally, there have been long-standing concerns raised for years by this trade publisher – MHProNews – and by MHARR regarding the need to fully implement the Duty to Serve by the GSEs.

 

Two Great Laws Already on the Books NOW,  Can Unlock Billion$ Annually for Manufactured Housing Industry Businesse$, Investor$

 

Since 2003, during an affordable housing crisis, the total number of manufactured homes being produced per year has declined.  So too has the percentage of new manufactured housing units.  The factors noted and linked from this report are among the contributing challenges that have arguably caused this to be so.

Publicly traded MHI member, Skyline Champion (SKY), is but one of several sources that point to the industry’s underperformance.  Do factors like those outlined and linked from this report help shed light as to why the industry is underperforming?  As but one of several internal and external barometers, RVs have soared in the last 2o years, while manufactured housing is but a shadow of what it was 2 decades ago in total sales.  Yet RVs are a luxury item, and housing is a necessity, the later point being made by voices across the political divide, such as Senator Warren and Secretary Carson, have pointed out.

 

ManufacturedHomeMHShipments1990-2017DailybusinessNewsManufacturedHousingMHProNews

Graphic by Skyline Champion, commentary by MHProNews.

 

But what federal officials may not have completely honed in upon is that during that contraction, Clayton has grown their market share, as the next two pie charts reflect.

ClaytonHomesOakwoodHomesBerkshireHathawayMarketShareofManufacturedHousingEndof2003DailyBuisnessNewsMHanufacturedHousingIndustryProNews

ClaytonHomesBerkshireHathawayMarketShareofManufacturedHousingEndof2011DailyBuisnessNewsMHanufacturedHousingIndustryProNews

Note the acceleration of Clayton’s consolidation, after the letter below by 21st was issued? That’s what some legal minds have called ‘smoking gun’ evidence of antitrust behavior.  Other evidence linked here reflects that the claims by Tim Williams were a mix of the truth and untrue. Rephrased, this was plausible cover for alleged antitrust law behavior.

21stMortgageCorpLogoLetterheadJan302009TimWilliamsRetailersBrokersCutSpecifiedLendingMonopolisticPloyConcernManufacturedHomeDailyBusinessNewsMHProNews

This document was provided as a news tip to MHProNews. To see the full report, click here.

 

ClaytonHomesSkylineChampionCavcoIndustriesMarketShareManufacturedHousingIndustryConsolidationGraphicPieChartMHProNews-e1528746976415

 

 

Coincidence? Or is it because Buffett’s bucks have – via third-party documented ‘dark money’ channels, has funded both the opposition to the industry by MHAction and other activist groups, as well as purportedly dominating MHI.

 

 

Prosperity Now, Nonprofits Sustain John Oliver’s “Mobile Homes” Video in Their Reports

 

This raises several issues that bear federal agencies, media and other investigations, and congressional oversight.

 

HUD Secretary Ben Carson, Affordable Housing, Obscuring the Truth, Innovations in Housing, and Manufactured Homes

 

Because there is a pattern and evidence that reflects the very real possibility that market manipulations and ‘predatory behavior’ by a small number of MHI member companies has cost the industry billions of dollars a year in potential sales.

 

Rope-a-Dope – Preserving Access to Manufactured Housing Act, Mom, Dad, & You

 

Is that an accident, mere coincidence?  Or is it indicative of something more sinister that often causes millennials and others to question capitalism, when it is specific and problematic corporate behavior that should be scrutinized, not the entire free enterprise system.

As tent cities grow in various parts of our nation, of course there will be an outcry by people against such troubling developments.

 

Tent Cities, Homelessness, Crime, Disease, Affordable Housing, and Manufactured Homes

 

While Secretary Carson and his predecessor have both praised manufactured homes, the inexplicable failure to use “enhanced preemption” or the “Affirmatively Furthering Fair Housing” legal principles to address these issues reflect some breakdown between the need and solutions that are already law.

It is mind boggling that MHI has no mention of enhanced preemption on their website, as of the date of the report linked below.  By contrast, MHARR, MHLivingNews, MHProNews and others have numerous articles and years of reports that point to that the need to enforce the law on federal preemption.

 

Members Point to Positives, Problematic – Manufactured Housing Institute (MHI) says, “Get the Facts on Zoning”

 

HUD Secretary Ben Carson, Affordable Housing, Obscuring the Truth, Innovations in Housing, and Manufactured Homes

 

Summing Up

Affordable housing, related lending, and a failure to properly promote manufactured housing are cited by people in and out of MHI as real problems.  This publication has stressed that not all MHI members should be viewed as black hats.  But that ‘black hat’ behavior has occurred from several prominent MHI member-firms is difficult if not impossible to intelligently dispute.

 

ManufacturedHousingInstituteLogoMHIBoardOfDirectorsLogoMHIExecutiveCommittee

Nathan Smith, Joe Stegmayer, Tim Williams, have all had various allegations lodged against them, as has Clayton Homes. Follow the links to learn more, which explains the satirical logo’s point.

 

Small Businesses, Consumers Are Being Harmed

These purported ploys in turn have cost small businesses collectively billions of dollars in the value of their enterprises. In response to declining shipments during an affordable housing crisis, which clearly harm smaller, more marginal businesses more than larger ones.  Bigger players with black hat behavior fuels bad news. The black hats may be using white hat companies in the same association to dress up their overall image.

MHI routinely has a reference to their antitrust statement – linked here – at the start of their individual business meeting sessions.  But that doesn’t change the reality that the industry is being consolidated into ever fewer hands.

To see if this is mere happenstance or something sinister if not illegal, federal, state, other interests, and advocates must do more to investigate beyond what has been done in articles like this and the linked reports herein and further below.

Secretary Carson has been doing a lot for manufactured housing publicly. But a counternarrative is also at play, which videos like John Oliver’s dwarf the good news that Secretary Carson is attempting to foster.  To date, the MHI ‘Homes on the Hill’ videos posted on this page have had about 2,000 total views between the 5 videos.  That’s helpful.  But John Oliver’s viral attack on manufactured housing has had over 6 million views.  That’s the factual reality.

Both major parties are making affordable housing and antitrust issues.

–      Will one party or both grab the bull by the horns, and investigate Berkshire Hathaway publicly?

–      Will one or both political parties call Warren Buffett, Kevin Clayton, and Tim Williams in to testify under oath about the evidence and allegations linked here?

–      Will federal and other investigators formally and publicly examine claims since the item linked above of further market manipulations, such as the ones reported at this link here?

–      Will the Feds and others allow Berkshire’s money and reputation to back them off? Or will they listen to voices that include MHI members who have said for years there is something wrong at the Arlington, VA based ‘umbrella’ trade group?

 

LATonyKovachGoodBipartisanshipShouldalwaysBepredicatedBenefitallhonestindustrymembersnotslectfewquote

The comment above was said with respect to another recent topic, but relates to this issue too.

Ponder the following 4 items from current-former MHI members.  On the issue of DTS, ponder the photo of MHI’s sponsors, and then MHARR’s comment about DTS.

 

TheHUDCodeforManufacturedHomesisADiscriminationCodeMartyLavinJDMHIAwardWinnerMHRetailFinanceExpertCommunitiesOwnerPhotoQuoteMHProNews

SoTheAssociationMHIIsNotThereFortheIndustryUnlesstheinterestsoftheBigBoysJointheIndustry'sMartyLavinMHIAwardWinnerQuoteMHProNews

MHProNews looks at the facts, considers the sources, and follows the evidence. MHI earlier last year, and for years before, MHI routinely replied promptly to all inquiries. But since we’ve spotlighted the problems and concerns, they’ve gone silent. Why? If the facts are on their side, why not make offer a cogent explanation?

 

FollowThe MoneyPayMoreAttentionToWhatPeopleDothanwhatTheySaySpySea72MartyLavinYachtManufacturedHousingINdustryProMHProNews

Ask yourself. Do these Marty Lavin dictums apply in this case?

 

 

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Marty Lavin advises, “Follow the Money” and “Pay More Attention to What People Do Than What They Say.” The GSEs are praising manufactured home quality, but then backed Clayton in supporting a ‘new class’ of manufactured homes, with key MHI member input, that is aimed at funneling that lending, per informed sources.

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The Trump Administration officials shown above could well find themselves the target of MHAction, or other similar activist group’s claims, that they are acting on behalf of the MHI’s largest companies. Indeed, MHI has implied as much in their ‘photo op’ messages to their own members. Are we to think that MHAction doesn’t already have these photos? MHAction and their affiliated groups have arguably already laid the foundation for that in their prior protests of Secretary Carson, and large MHI members, as the video with Senator Warren above illustrates. To be clear, MHProNews is not accusing these officials of any wrongdoing, but rather, we are hereby pointing out the on issues such as DTS, Enhanced Preemption, or Affirmatively Further Fair Housing, failure to fully and properly address those as federal law already requires could leave well meaning photo ops to be twisted into something that those officials never imagined. To learn more, click here.

 

Let’s dot the i on the above by saying anew that in pointing the finger at the Omaha-Knoxville-Arlington axis, that is not to be misconstrued as saying that all of those in said organizations are all tainted.  Among our sources are those in Clayton Homes, 21st, and MHI, to name but a few.  There are good people working in these organizations who are as troubled by what is occurring to the industry as we and others are.

 

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Millions of Americans are trapped in rentals, largely unaware of the good news that Secretary Carson has said during his tenure at HUD, or what scores of others in manufactured housing have been saying for years. Will MHI take these helpful videos that Secretary Carson made possible, and robustly promote them?  Or will they be a mere fig leaf? The latest head-fake to members, another illusion of motion, while the industry continues to consolidate?  Meanwhile,  millions search for affordable housing, when the solution is hiding in plain sight?

VicePresidentMikePenceWifeKarenHandOverHeartPledgeColts49ersGameWashingtonTimesDailyBusinessNewsMHProNews

Notice. One can agree or not with 21st Mortgage CEO and prior MHI Chairman Tim Williams’ presentation, from which the slide above was taken with permission, while still questioning how it came to be that Williams was being intellectually at odds with Berkshire Hathaway Chairman, Warren Buffett. To see all of William’s informative slides, click the graphic above. http://www.MHProNews.com/industry-news/industry-in-focus/is-tim-williams-21st-mortgage-ceo-mhi-chair-at-odds-with-berkshire-hathaway-chairman-warren-buffett What is undisputable is that for years, MHI pursued a bill that their own SVP of Government Relations said had essentially no chance of passage. Where was the logic? Or was it a ‘rope-a-dope‘ ploy?

 

But there is a rationale case to be made that forces within the industry have intentionally limited the industry, with the purported aim of consolidating businesses at a discount in a fashion that might slip by antitrust regulatory scrutiny.

 

Enforce Existing Law

But as or more important is that the solution requires no new legislation.  The solution is already federal law.  It need but be enforced. But there is evidence that the powers that be in the industry don’t want to solve the problem now.  They want to consolidate more of the industry. Meanwhile, the suffering of millions of people and thousands of independent business professionals continues.

 

UnderstandingWarrenBuffettCastleMoatMetaphorsQuotesDailyBusinessNewsMHProNews

Never forget that even during medieval times, castles and their moats were in fact breached. MHProNews and our sister site continue to chop away at the core issues that are close to the heart of what is arguably keeping manufactured housing from achieving its potential.

WarrenBuffettAZQuoteCriticalFactorDetermineValuePayFairBargainPriceMHProNews

GoodBusinessIsLikeAStrongCastleWithaDeepMoatAroundItSharksIntheMoatIwantItUntouchableWarrenBuffettQuoteDailyBusinessNewsMHProNews

Sometimes the truth is hiding in plain sight. Follow the facts, evidence, and the money.

 

Thus a public federal investigation, led by Congress, but with parallel efforts in the federal agencies, needs to be handled as publicly as possible. Why? Because the harm being done to the manufactured home industry is harming the public, plus independents who are arguably a victim too.

Renters, manufactured home owners, and voters need to understand that this is consolidating Machiavellian ploy is harming their interests.  The industry’s honest professionals should not be punished, it is the alleged bad actors who need to be held to account.

If we as a nation do so, then Secretary Carson’s solution for America may come to pass. The fabled doctor’s prescription, if put to work, could prove useful to millions and would save taxpayers billions too.  It would also create countless new jobs, and spark new investment opportunities.

ValuePenguinFearManufacturedHomesSolutionAffordableHousingCrisis

https://www.valuepenguin.com/home-insurance/fear-manufactured-homes-affordable-housing-crisis If MHI were serious about growing the industry, why have they not spotlighted articles like the one linked above?

 

The reports linked herein plus those below the byline and notices include articles that document how a natural economic boom could take place, raising the net worth of individuals who could leave the world of renting and become owners of affordable housing’s most obvious and proven solution. Modern manufactured homes are a proven solution. There is much work to be done to make that prescription and potential a reality.

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Gus’ message came in response to a series of exposes on issues within manufactured housing, as well as tips, strategies, and opportunities.

To learn more, see the reports linked above and below. More on this simple yet-profound topic tomorrow and in the days ahead. No politics, just 311 words that boil down to two words. Enhanced preemption. “We Provide, You Decide” © ## (News, analysis, and commentary)

(See Related Reports, further below. Text/image boxes often are hot-linked to other reports that can be access by clicking on them. Third-party images and content are provided under fair use guidelines.)

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Two Great Laws Already on the Books NOW,  Can Unlock Billion$ Annually for Manufactured Housing Industry Businesse$, Investor$

 

Tim Sheahan, NMHOA President, Controversial Points of Agreement with Marty Lavin, George Allen on Communities

Conquest Capitalism – Thoughts of Chairman Warren Buffett – Billionaires Campaign to Control Trillion Dollar Affordable Housing Market

 

Shocking, True State of the Manufactured Housing Industry, plus Solutions for Profitable, Sustainable Growth – May 2019

 

 

 

 

 

“Fight Like Hell” for Independence, Says Trustee – Manufactured Housing Inspiration?

April 3rd, 2019 Comments off

 

FightLikeHellForIndependenceSaysTrusteeManufacturedHousingInspirationDailyBusinessNewsMHProNews600

The story from the Boston Globe has nothing on the surface to do with housing, much less factory-built housing. But it had much to do with independence, and the willingness to fight in an arguably increasingly monopolistic, manipulated or ‘rigged system’ society.  Who says? The New York Times, see the column, linked here.

 

A snapshot from outside of our manufactured home industry is worthy of a few moments consideration to gird you or others as to the nature of the struggle – and the inspiration needed – to the good fight for independence.  Because manipulation and ‘rigged systems’ are not only found in our industry, they are increasingly evident elsewhere too.

Here’s what the left-of-center Boston Globe sent to the Daily Business News on MHProNews yesterday, and we’ll then look at what this tale should inspire in our industry’s professionals, investors, and others keen on affordable housing for millions of Americans.

 

BostonGlobeTwoTrusteesQuitDiscordHampshireCollegeFutureDailyBusinessNewsMHProNews

Two Hampshire College trustees have resigned in recent weeks, a result of the increasing acrimony enveloping the board as it charts an uncertain future for the liberal arts school.

Gaye Hill, the board chairwoman, resigned this week, saying she had become a lightning rod. Another trustee, Mingda Zhao, also stepped down, saying he was forced out.

Zhao’s resignation letter offers a hint about what’s next for the private Amherst college. It says board leaders seem to be pushing for the school to close and be acquired by another institution. But he said it is also possible to “fight like hell” to keep the school open and independent,” said the Boston Globe, in an article linked here.

MingdaZhaoHampshireCollegeDailyBusinessNewsMHProNews

 

What Zhao is describing, per the Boston Globe, is what could be called a backstab of the college by various people with ‘special interests,’ including other members of its own board of directors. Stop and think. How is that different than the Manufactured Housing Institute (MHI) being accused of betraying the interests of the independents in the manufactured housing industry?

 

Yesterday two different reports came into MHProNews from two different sources that represent different parts of the manufactured housing industry.  One came in from NAHMCO, the National Association of Manufactured Housing Community Owners. Another came in and had already been published from the Manufactured Housing Association for Regulatory Reform (MHARR).  ICYMI, see the linked text-image box below for that report.

 

Historic Manufactured Housing Industry Decisions Were Made Here on 3.27.2019

 

While entirely different, each one reflects a vote of no-confidence by their respective associations and members in the so-called leadership of Arlington, VA based MHI.

Washington, D.C. based MHARR cites post-production issues that the see MHI as having not only failed at, but arguably having manipulated against the interests of the majority of firms in the manufactured home industry.  Among the points they made was diversion of Duty to Serve (DTS) financing by the Government Sponsored Enterprises (GSEs) away from the majority of manufactured homes into an untested program promoted by industry giant Clayton Homes. Clayton, a Berkshire Hathaway brand along with others in the manufactured home industry, is widely seen as dominating MHI, along with other ‘big boy’ companies, as MHI award winner Marty Lavin, JD, has put it.

NAMHCO also cited DTS yesterday and the need to obtain more market rate financing. The NAMHCO statement bears some clarifying, which MHProNews plans to do in the days ahead before publishing their full document.  But it is noteworthy that NAMHCO – still in its infancy – and MHARR, decades established, de facto or explicitly take a viewpoint contrary to the happy talk fed by MHI to their members and state association affiliates.

 

Why Is There a Need to Fight to Implement Existing Laws?

That existing laws have to be fought to get them properly implemented is itself an outrage. Manufactured housing enjoys some of the finest federal laws that consumers or the industry’s honorable professionals could want.

The reality is that those laws are not being implemented. Cities and local jurisdictions are increasingly limiting or banning manufactured housing. And when one pulls back the veil on why those laws are not being implemented, time and again, there is evidence that a Berkshire brand or other MHI connected firm is benefiting at the expense of independents.

Barbara Hames of Hames Homes in Iowa may or may not have thought much about the fact that Havenpark Capital is an MHI member. She may or may not have thought much about how the apparent collusion between 21st and Clayton Homes, with no warnings from MHI, arguably harmed the interests of the communities she has now sold. Would Hames have sold at all, in the absence of the market manipulation by 21st, Clayton Homes, and Warren Buffett led Berkshire Hathaway documented at the link here?

 

Where Was The Buffett Mantra in Tunica Last Week?

What independent industry professionals and others must consider is this question. When Warren Buffett preaches the importance of protecting a firm’s reputation, why did Clayton, 21st and MHI all decline to attend the meeting of independents? Those independents wanted to hear first-hand what the counter argument might be to the documents and video linked above and here. Those independents wanted to hear that directly from the horses mouth.

Why did Clayton, 21st, MHI, Fannie Mae, et al stay silent?

Those manufactured home industry independents – including representatives from MHARR and NAMHCO.  They and those in attendance reflected the interests of some 200 industry locations.  They were there to begin the process that NAMHCO started some 2 years ago, or that MHARR began decades ago.

Like Zhao urged those that want to save their college from a takeover, the independents of manufactured housing must “fight like hell” if they want to stay independent.  How else will they survive the purported market manipulations and failures to act that the Omaha-Knoxville-Arlington axis and their allies stand credibly accused of, and failed to respond to once more in Tunica last week. Their trade media surrogates likewise opted not to attend, is it any surprise?

Susan Brenton told the independents there at Tunica that she saw value to their doing what NAMHCO has already started. It is worth noting that NAMHCO, as a post-production association, has a D.C. lobbyist, but not Washington metro office at this time.  That’s a reminder that a post-production trade group has no specific need for a costly D.C. metro office.

While there are obvious expenses to forging a new non-producers trade body, it is modest compared to the potential upside. The ‘Axis’ in manufactured housing obviously hopes it is never formed, as former MHI chair Nathan Smith quickly slammed NAMHCO in a written statement a few months ago, as the article linked further below the byline and notices reminds readers.

Affordable housing isn’t a partisan issue. It matters not if the person fighting for affordable manufactured homes is a Democrat, Republican, or an Independent. That is underscored in another article linked below.

Democrats, Republicans Agree – “Manufactured Homes Can Play a Vital Role in Easing” the Affordable Housing Shortage

The fear tactics, restraint of trade, manipulation of access to financing and other methods arguably being employed by specific Omaha-Knoxville-Arlington connected brands have arguably cost the industry’s professionals tens of billions of dollars since Warren Buffett made the move in 2003 to buy Clayton and it’s affiliated lenders, and control other organizations.

Fortunately, Berkshire has the deep pockets to pay those billions. Instead of proposing problematic or unconstitutional wealth taxes, and other floated notions by 2020 candidates, why don’t they focus their energy and talents on something that is doable, legal and useful?

 

Who Will Act? Will Senator Elizabeth Warren, and/or the Trump Administration Act to Restore Open Markets, Thereby Supporting Affordable Manufactured Homes?

 

Why not break up Berkshire, do whatever the law allows with MHI, and fine them billions as the EU has Google for violations of antitrust and other laws?  Why not make an example of them, so that others won’t be tempted to so manipulate this industry or any other ever again?

As independents begin the process of organizing, the time is now.  Like Zhao suggested in his scenario, one must fight like hell, for a heavenly cause.

That’s this morning’s first look at “News Through the Lens of Manufactured Homes, and Factory-Built Housing” © where “We Provide, You Decide.” © ## (News, analysis, and commentary.)

 

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DTS Manufactured Home Lending Committee Member Says MHI in “Unholy Alliance” to Divert Needed GSE Support Away from Manufactured Housing

White Collar Shakedown, Fear, Hobbs Act, and Manufactured Housing Independents Struggles

 

State Level Shipment Data Continues to Flash Warning Signals for New HUD Code Manufactured Housing Sales

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Errata, Apologies, Explanations, Tunica Talk, and Manufactured Housing

MHI’s Growth Agenda? Rick Robinson, JD, SVP Manufactured Housing Institute, Preemption Evidence, Writ of Mandamus, and Addressing HUD Code Manufactured Home Shipment Woes

 

Sun Tzu – Ultimate Manufactured Home Freedom Alliance

 

 

 

 

 

 

 

HUD Secretary Carson “HUDdle Conference” Draws Manufactured Housing Issues Engagement

March 21st, 2019 Comments off

HUDSecretaryBenCarsonHUDdleCOnferenceDrawsManufacturedHousingIssuesEngagementDailyBusinessNewsMHProNews

The Daily Business News on MHProNews learned that the Department of Housing and Urban Development (HUD) Secretary Ben Carson, M.D., kicked off their latest ‘HUDle’ meeting at their Washington, D.C. office building.

 

In a statement to MHProNews, here is what the Manufactured Housing Association for Regulatory Reform (MHARR) said today.

MarkWeissJDPresidentCEOManufacturedHousingAssocRegulatoryReformDailyBusinessNewsMHProNewsThe Department of Housing and Urban Development, on March 20, 2019, held the latest in a series of “HUDdle” conferences with invited HUD-program stakeholders.  The conferences, which are an initiative of — and hosted by — HUD Secretary Ben Carson, focus on emerging issues at the Department, including, but not limited to, aspects of its ongoing regulatory reform process,” MHARR said.

Among the manufactured home industry professionals present was Mark Weiss, JD.  Weiss is the president and CEO of MHARR.

MHARR’s president emphasized the urgent need for HUD to address and resolve two key issues that continue to suppress the availability of inherently affordable manufactured housing for millions of American consumers, and the economic growth of the industry,” per their statement, which added, “Those two issues are, first, discriminatory zoning laws that exclude or severely restrict the placement of manufactured homes in large areas of the country.  The second is the critical need for reform at Fannie Mae, Freddie Mac and the Federal Housing Administration (under the “Duty to Serve” and beyond), to substantially increase the availability of manufactured home consumer financing (and especially personal property or ‘chattel’ financing) to market-significant levels.”

 

MHARR stated that they will be following-up soon with relevant HUD officials to further pursue these key policy objectives.

 

The issues come in the wake of fact-checks and related exposes by MHProNews, which included specific examples of the post-production Manufactured Housing Institute (MHI) was routinely failing to address specific cases spot-checked by MHProNews. Here accessible via the linked text-image box is but one example. Others follow below the byline, disclaimers, and notices.

 

MHI’s Growth Agenda? Rick Robinson, JD, SVP Manufactured Housing Institute, Preemption Evidence, Writ of Mandamus, and Addressing HUD Code Manufactured Home Shipment Woes

 

Placement and financing are post-production, not production related issue, so they fall into MHI’s self-proclaimed bucket of representing “all segments of factory-built housing.”  Topics like this and others will be among the issues addressed at the rapidly approaching “Fix the MH Industry Trick$” meeting a week from today Thursday afternoon at the Tunica Manufactured Housing Show.

That’s this afternoon’s manufactured housing industry “News, Tips, and Views Pros Can Use” © where “We Provide, You Decide.” © ## (News, analysis, and commentary.)

 

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As Affordable Housing Crisis Rages, New HUD Code Manufactured Housing Shipments Fall, Some States Drop 35-40 Percent

Cha-Ching! Manufactured Housing Made Simple in 2019

 

Fix MH Industry Trick$ – Special Meeting at Tunica Show

 

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Local Star Chambers Wage War on Affordable Housing

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HUD Code Manufactured Home Production Decline Persists – Time For Action Not Excuses

MHARR Calls on HUD To Remove Zoning, Placement and Consumer Financing Barriers to Manufactured Homes

“The Illusion of Motion Versus Real-World Challenges”

 

 

 

 

 

 

 

 

 

DTS Manufactured Home Lending Committee Member Says MHI in “Unholy Alliance” to Divert Needed GSE Support Away from Manufactured Housing

March 12th, 2019 Comments off

 

WhisleblowerDTSManufacturedHomeLendingCommitteeMemberSaysMHIUnholyAllianceDivertNeedLendingfromManufacturedHousingDailyBusinessNewsMHproNews

The source of the following memo is known to have served on one or more Duty to Serve (DTS) committee(s) with the Government Sponsored Enterprises (GSE) of Fannie Mae, Freddie Mac, other Manufactured Housing Institute (MHI) staff, and MHI member companies that participated in various discussions about access to lower cost lending for manufactured homes.

 

Never forget, not every MHI member agrees with what the Arlington, VA based trade group is doing.

The memo itself says it was not for attribution, meaning it was sent to MHProNews publisher L. A. ‘Tony’ Kovach for consideration of coverage on an ‘off the record’ basis.

The edits by the Daily Business News are shown in brackets, for example, to make clear that the sender provided an article from Housing Wire and was commenting on it.

The memo raises several troubling concerns that parallel issues that MHProNews has previously spotlighted. First, here’s the text of the memo to MHProNews.

 

Tony:

[I] offer the following points with respect to the article…[below from Housing Wire] on GSE reform and MHI signed on to – and thereby promoting — a “go slow” approach. These are not for specific attribution…but point out the hypocrisy inherent in MHI’s conflicting positions:

1.     How can MHI claim to be pressing the GSEs to implement DTS in a timely fashion, when they simultaneously advocate a “go slow” approach to needed GSE reforms overall? 

2.     How can MHI align itself with the site-built industry, which does not want GSE reform to negatively impact their much larger purchase-money loans (thus the overly-cautious go-slow approach), when the HUD Code manufactured housing industry wants and needs – on an expedited basis – GSE support for its much smaller consumer loans?

3.     This amounts to an “unholy alliance” between MHI and the site-built industry, which is trying to preserve its virtual monopoly on GSE support.

4.     This, however, is consistent with – and would seem to confirm – that MHI and large HUD Code manufacturers have cut a bargain with the GSEs and FHFA to divert much of DTS to a euphemistic “new class” of homes, which are not mainstream, affordable, manufactured homes (and particularly not chattel-financed manufactured homes).

5.     How can MHI claim to be working in Congress to enact beneficial reforms for the HUD Code industry when they are simultaneously trying to effectively slow-roll reforms that have already been mandated by Congress as part of DTS?

Conclusion: There can be no legitimate or acceptable private explanation or excuse by MHI behind closed doors for the predicament that they’ve placed the industry in with this action.  Instead, the inherent hypocrisy must be exposed and openly debated.”

  

MHI, Clayton and their allies have ducked such debate before.  The memo’s commentary and analysis draws to a conclusion with the words, “See the full article below.” That article by Housing Wire said the following, and is provided under fair use guidelines that apply for media.

 

FHFAFederalHousingFinanceAgencyDailyBusinessNewsMHProNews

Shown for illustration purposes, this isn’t directly related to Housing Wire’s report.

Housing industry to FHFA: Go slow on GSE reform

Letter encourages agency to make affordable housing a priority

March 6, 2019

By Kelsey Ramírez

 

Talk of housing reform is heating up, and now several members of the housing industry are encouraging the Federal Housing Finance Agency not to go too fast, and to make sure affordable housing remains a priority throughout the process.

 

Many key members of the housing industry sent a letter to the FHFA, encouraging it to build on the current structure of the government-sponsored enterprises Fannie Mae and Freddie Mac.

 

“As the Federal Housing Finance Agency (FHFA) begins its next chapter under new leadership, our organizations seek to emphasize the vital role that Fannie Mae and Freddie Mac, the Government-Sponsored Enterprises (GSEs), currently play in the mortgage market,” the letter, addressed to FHFA Acting Director Joseph Otting, said. “There is a unique opportunity today to maintain and build on important progress that has already been achieved in reforming the operations of the GSEs since the financial crisis.”

 

The letter states that GSE reform and an end to the conservatorship is ultimately necessary in order to ensure the safety and soundness of the housing market.

However, the letter encourages policymakers to act slowly and carefully.

 

“Any efforts to meaningfully change the GSEs’ market presence must be undertaken carefully, with vigilant monitoring and frequent recalibration (if necessary) to avoid disruptions to the flow of mortgage credit into the single-family and multifamily real estate markets,” it states. “Efforts to reduce the GSEs’ footprint should not move forward unless there is compelling evidence that the private market is able to assume an expanded role.”

 

The housing industry argued that GSE reform should accomplish two key objectives:

 

1. Preserving what works in the current system

2. Maintaining stability by avoiding unintended adverse consequences for borrowers, lenders, investors or taxpayers.

 

“Recognizing the vital role that the GSEs currently play, it is critical that any administrative reforms do not disturb essential functions in the secondary mortgage market,” the letter said. “Policymakers must take great care that actions to institute reforms to the GSEs are prudently developed and implemented over a sensible time horizon.”

 

The letter asks that housing finance reform maintain the 30-year fixed-rate mortgage in the single-family market. It also asks that the GSEs still be required to meet the needs of underserved markets and support affordable housing.

 

“We urge policymakers to take these principles into account to ensure that access and affordability are preserved under the current, and any future, housing finance regime,” the letter concludes.

 

The Senate Committee on Banking, Housing and Urban Affairs recently voted to advance the nomination of Mark Calabria as director of the FHFA to a full Senate vote.

 

Previously, Calabria famously called for the end of the conservatorship of Fannie Mae and Freddie Mac. Click here to read more about what Calabria as director of the FHFA would mean for the future of the GSEs.

 

Now, many think that GSE reform could be on the verge of becoming a reality.

 

The letter was signed by: the Asian Real Estate Association of America, the Consumer Federation of America, the Consumer Mortgage CoalitionEnterprise Community PartnersHabitat for Humanity International Leading Builders of AmericaLocal Initiatives Support Corporation Make RoomManufactured Housing Institute Mercy Housing, the Mortgage Bankers AssociationNareit, the National Apartment Association, the National Association of Affordable Housing Lenders, the National Association of Hispanic Real Estate Professionals, the National Association of Home Builders, the National Association of Real Estate Brokers, the National Association of Realtors, the National Community Stabilization Trust, the National Council of State Housing AgenciesNational Housing ConferenceNational Housing Trust, National League of Cities, the National Multifamily Housing Council, The Real Estate Roundtable, the Real Estate Services Providers CouncilStewards of Affordable Housing for the Future and Up for Growth Action.

 

Click here to read the letter in full.

 

—- End of Housing Wire article sent by confidential source to MHProNews —-

DUTYtoServePaulBarrettoFannieMaeManufacturedHousingIndustryDailyBusinessNewsMHProNews550

It must be recalled that Fannie Mae’s Paul Barretto told MHProNews in front of dozens of industry professionals that neither 21st Mortgage Corp, nor Vanderbilt Mortgage and Finance (VMF) provided data to the GSEs to help them launch a chattel loan program. By contrast, other MHI member lenders did. That begs the question, why did the Berkshire Hathaway brands work to foil lending on ‘regular’ manufactured homes, while diverting GSE lending to the Clayton Homes backed “new class of homes?” MHI and official voices in Knoxville are mute on those types of #NettlesomeThings questions. http://www.mhpronews.com/blogs/daily-business-news/fannie-maes-paul-barretto-news-making-remarks-in-tunica/

 

Additional Concerns This MHI Memo Raises?

To set the context for this analysis, a similar prior case that also involved lending will be recalled. 

In 2015, MHProNews’ publisher – acting on a tip from within MHI – publicly called out Manufactured Housing Institute (MHI) President and CEO Richard ‘Dick’ Jennison and MHI SVP Lesli Gooch for attempting to deliberately mislead their own members. The subject of the alleged deception was a Senate hearing with then Consumer Financial Protection Bureau (CFPB) Director Richard Cordray regarding the MHI backed Preserving Access to Manufactured Housing Act.  Recall that Preserving Access was never passed.

But at that time, MHI had issued an emailed statement to their members that was accurate in quoting then Senator Joe Donnelly (IN-D), but failed to mention the pushback from Cordray, or other key parts of the full discussion. Those omissions by MHI to their members completely changed the meaning and context for what had actually occurred in that hearing. MHI postured progress, but in fact no progress had occurred. The MHI source provided CSPAN video to back up their contention that MHI was deliberately misleading their own members, and through MHI state affiliates, the Arlington, VA based trade group was misleading the industry at large.

 

JasonBoehlertManufacturedHousingInstituteSeniorVPLogoMHIlogoQuoteMHProNews

In hindsight, which Warren Buffett reminds us that the rear view mirror is clearer than the windshield, it is now clear that the MHI plan for Preserving Access was filled with contradictions and purported head fakes. It didn’t matter to the powers that be if Preserving Access passed or not. But as the Jason Boehlert quote above reminds readers, it wasn’t expected to pass. So why did MHI spend millions in the effort? http://www.mhmarketingsalesmanagement.com/blogs/industryvoices/2012-election-results-and-coming-lame-duck-session/

 

Based upon the evidence presented, which MHI did not dispute, a column by Tony Kovach called Jennison and Gooch out for their alleged attempt at the deception of the industry and the Arlington, VA based trade association’s own members, and asked for their resignation and or termination. But instead, then MHI Chairman Tim Williams, who is president and CEO of Berkshire Hathaway owned 21st Mortgage Corp, arranged for a vote of confidence in Jennison.

 

VicePresidentMikePenceWifeKarenHandOverHeartPledgeColts49ersGameWashingtonTimesDailyBusinessNewsMHProNews

Notice. One can agree or disagree with 21st Mortgage CEO and prior MHI Chairman Tim Williams’ presentation, from which the slide above was taken with permission, while still questioning how it came to be that Williams was being intellectually at odds with Berkshire Hathaway Chairman, Warren Buffett.  Why were millions spent, when Buffett was clearly ‘tight’ with then President Barack Obama? Why spend millions lobbying for Preserving Access, when then President Obama said he’d veto it if it ever hit his desk?

 

WarrenBuffettBarackObamaWikipediaMotherJonesDailyBusinessNewsMHProNews

Buffett was a strong supporter of candidate and President Obama. Obama in turn was a strong support of Dodd-Frank, and not changing the CFPB. See related, linked below. http://www.mhpronews.com/blogs/daily-business-news/manufactured-housing-institute-vp-revealed-important-truths-on-mhis-lobbying-agenda/

 

Rephrased, instead of holding those two senior MHI leaders accountable for deception, Jennison and Gooch were defended and retained by the direct and specific intervention of Williams, Clayton Homes representative on the executive committee, and others who align with them.

The Daily Business News on MHProNews has noted more than once that Jennison and Gooch were given bonuses for their work, according the federal document filings by MHI and confirmed by MHI’s CEO Jennison. Again, MHI staff nor MHI Executive Committee leaders have not denied those bonus payments to Jennison, Gooch, or others.  You can access the report below by clicking on the hot-linked text-image box. 

 

Bonuses, Bonuses! Manufactured Housing Struggles During Affordable Housing Crisis, While Top MHI Staffers Get Bonuses

 

The letter reported by HousingWire and signed onto by MHI to FHFA Acting Director Joseph Otting, is arguably a double cross of the claims that MHI has been making even recently to the industry.  When MHI claims that they are acting to expand lending on manufactured housing, it is arguably demonstrably untrue.  See the “Illusion of Motion” further below. 

Without contradicting the source that sent the memo and tip above, the scenario that source describes is arguably far more corrupt than that DTS committee source alleges.

MHProNews will be asking for MHI, MHARR, and federal officials to react to this report now that it is published.

But equally important, this is the latest piece of evidence that seems to confirm what Marty Lavin, JD, former MHI member and award winner, previously said to MHProNews. Namely, that the so-called big boys get their way, and the rest of the industry only benefit from MHI when the big boy interests happen to align with independents.

   The manufactured home industry is struggling during an affordable housing crisis.

   There is mounting evidence that the Omaha-Knoxville metro powers have purportedly weaponized MHI and other operations in a manner that is contrary to the interests of the vast majority of other independent firms in the industry.

   DTS was clearly diverted to the “new class of homes” lending that MHI sources have told MHProNews was initiated by Clayton Homes. Leaders from MHI only member production firms have complained that this is an abuse of the industry’s most affordable housing, and that the ploy is aimed to benefit Clayton while harming others.

MHProNews will continue to unpeel the onion as more details emerge. See the related reports below, for more on Duty to Serve and finance related issues.

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“Waste, Fraud, and Abuse” – FHFA, GSE Federal Oversight Announcement

Update on Fannie Mae Lobbying, and Manufactured Housing Controversy

Duty To Serve, “Complete Waste of Time” per Tim Williams, CEO/21st Mortgage; POTUS Trump, Warren Buffett Insight$

MHI Lender Shakes Up DTS and MLO Rule Discussions

“Thou Shall Not Steal,” $2 Trillion Annually Lost to Lack of Affordable Homes, Making the Manufactured Home Case

Manufactured Housing Association for Regulatory Reform (MHARR) Pressing Fannie Mae, Freddie Mac to Fully Engage on Duty To Serve (DTS)

Chairman Hensarling, Fannie Mae’s Latest “Backdoor Schemes,” Illegalities? MH Connections, Implications

GSE Asked: Will Manufactured Housing Overtake Conventional Homebuilding?

 

Fannie Mae Reports Billions in Manufactured Home Community Deals, Details Others Lack

January 25th, 2019 Comments off

 

FannieMaeReportsBillionsManufacturedHomeCommunityDealsDetailsOthersLackDailyBusinessNewsMHProNews

In a release to the Daily Business News on MHProNews, Fannie Mae (OTCQB: FNMA) said that they have “provided more than $65 billion in financing to support the multifamily market in 2018 with its Delegated Underwriting and Servicing (DUS®) program. Fannie Mae continued to serve as a key source of liquidity by attracting a diverse investor base to purchase our DUS Mortgage-Backed Securities (MBS), while building a profitable and sustainable book of business.”

 

For more than 30 years, the DUS platform has brought stability to the multifamily market. Our innovative thinking is driving the industry forward and our commitment to serving our customers remains our top priority,” said Jeffery Hayward, Executive Vice President of Multifamily, Fannie Mae. “Our lender partnerships are also propelling Fannie Mae to be part of a global movement to transform rental housing to be healthier for residents and to help reduce energy and water consumption at the properties we finance.”

The Government Sponsored Enterprises (GSE) of Fannie Mae and Freddie Mac have both been given some latitude by the Federal Housing Finance Agency (FHFA)) for using certain qualifying loans on manufactured home communities as credits toward their Duty to Serve (DTS) requirements. Right or wrong, that use of DTS has been far more robust than it has toward single family manufactured home loans.

Fannie Mae was recognized in 2018 as the largest issuer of Green Bonds in the world, with more than $20 billion in Green MBS backed by either green certified properties or properties targeting a reduction in energy or water consumption. Fannie Mae increased its Green Financing portfolio to over $50 billion in 2018, driven by $20 billion in Green Financing. In 2018, Fannie Mae made LIHTC equity investment commitments towards meeting FHFA’s $500 million volume cap by deploying equity to rural and other underserved housing markets throughout the United States. Additionally, Fannie Mae led the affordable market with overall production of $7.4 billion, an increase of 9% from 2017,” stated their release to MHProNews.

Multifamily had another outstanding year in 2018, thanks to our lenders,” said Rob Levin, Senior Vice President for Multifamily Customer Engagement, Fannie Mae. “Together, we supported all market segments, bringing liquidity to the market, while building a balanced portfolio that reflects our strategy with strong credit quality and mission-rich business.”

The following list are the top 10 DUS Lenders produced the highest business volumes in 2018. Also listing that follows also includes the Top 5 Lender rankings for highest volumes in 2018 for Multifamily Affordable Housing, Small Loans, Green Financing, Seniors Housing, Structured Transactions, Manufactured Housing Communities, and Student Housing:

 

Top 10 DUS Producers in 2018             Volume ($Billion)

  1. Wells Fargo Multifamily Capital                      $8.1
  2. Walker & Dunlop, LLC                                    $6.9
  3. Berkadia Commercial Mortgage, LLC             $6.6
  4. CBRE Multifamily Capital, Inc.                        $6.1
  5. Newmark Knight Frank                                    $4.3
  6. Greystone Servicing Corporation, Inc.            $3.9
  7. Capital One, National Association                   $3.8
  8. KeyBank National Association                         $3.4
  9. PGIM Real Estate Finance                              $3.3
  10. Arbor Commercial Funding I, LLC                   $3.2

 

Top 5 DUS Producers for Multifamily Affordable Housing in 2018

  1. Wells Fargo Multifamily Capital
  2. CBRE Multifamily Capital, Inc.
  3. Greystone Servicing Corporation, Inc.
  4. PGIM Real Estate Finance
  5. Jones Lang LaSalle Multifamily, LLC

 

Top 5 DUS Producers for Small Loans in 2018*

  1. Greystone Servicing Corporation, Inc.
  2. Arbor Commercial Funding I, LLC
  3. Hunt Mortgage Group
  4. Walker & Dunlop, LLC
  5. Bellwether Enterprise Real Estate Capital, LLC

 

Top 5 DUS Producers for Green Financing in 2018

  1. Berkadia Commercial Mortgage, LLC
  2. Greystone Servicing Corporation, Inc.
  3. Arbor Commercial Funding I, LLC
  4. CBRE Multifamily Capital, Inc.
  5. Capital One, National Association

 

Top 5 DUS Producers for Seniors Housing in 2018

  1. Berkadia Commercial Mortgage, LLC
  2. Grandbridge Real Estate Capital, LLC
  3. Capital One, National Association
  4. CBRE Multifamily Capital, Inc.
  5. M&T Realty Capital Corporation

 

Top 5 DUS Producers for Structured Transactions in 2018

  1. Wells Fargo Multifamily Capital
  2. Newmark Knight Frank
  3. Walker & Dunlop, LLC
  4. PNC Real Estate
  5. Berkadia Commercial Mortgage, LLC

 

Top 5 DUS Producers for Manufactured Housing Communities in 2018

  1. Walker & Dunlop, LLC
  2. Wells Fargo Multifamily Capital
  3. KeyBank National Association
  4. Berkadia Commercial Mortgage, LLC
  5. Capital One, National Association

 

Top 5 DUS Producers for Student Housing in 2018

  1. Wells Fargo Multifamily Capital
  2. Walker & Dunlop, LLC
  3. CBRE Multifamily Capital, Inc.
  4. PGIM Real Estate Finance
  5. KeyBank National Association

 

Listed below are 2018 production highlights for individual business categories, which are included in the total multifamily production number.

  • Affordable Housing – $7.4 billion comprised of $6.0 billion in Multifamily Affordable Housing (for rent-restricted properties and properties receiving other federal and state subsidies), an increase of 10 percent from $5.4 billion in 2017; and $1.4 billion for properties with rent restrictions between 60 percent and 80 percent AMI, in line with $1.4 billion in 2017
  • Small Loans* – $2.2 billion
  • Green Financing – $20.1 billion (properties with Green Building Certifications or loans targeting a 25 percent reduction or more in energy or water consumption)
  • Student Housing – $2.7 billion
  • Structured Transactions – $9.5 billion
  • Seniors Housing – $2.3 billion
  • Manufactured Housing Communities – $2.9 billion, an increase of 56 percent from $1.9 billion in 2017

Footnotes:

*Small Loans are defined as loans of $3 million or less nationwide and $5 million or less in high-cost markets, and typically finance multifamily properties with five to 50 units.

**Due to rounding, amounts reported may not add up to overall totals.

The above is insightful on several levels.  First, note that more than one of those manufactured home community DUS lenders has ties to Berkshire Hathaway.

Next, is that this is arguably part of the give-take mechanism that Arlington, VA based Manufactured Housing Institute (MHI) has used to get some of their community members in the National Community Council (NCC) to swallow and ignore the single-family chattel lending that the Manufactured Housing Association for Regulatory Reform (MHARR) has stressed should be at the core of DTS by the GSEs.

 

MHARRMarkWeissIfCongressHadMeanttheDutytoServeToBeOptionItWouldNotHaveCalledItADutyDefintionofDutyIsMandatoryResponsibilityDailyBusinessNewsMHProNews

 

It also brings back into focus what some in manufactured housing call the “sell-out” or “betrayal” of the industry’s independent producers of manufactured homes. How so?  Consider this from Fannie Mae’s own site, which stresses their ‘support’ for manufactured housing as:

  1. A) The Multifamily Manufactured Housing Communities Market . …
  2. B) Develop an enhanced manufactured housing loanproduct for quality manufactured (homes)…

It must not be forgotten that MHI leaders held closed door meetings with Fannie and Freddie, to which none of the parties have released the meeting minutes, that ultimately resulted in the “new class of homes” program that has emerged…

…and so far has landed with a thud.  While Fannie and Freddie are both mum on specifics, the new HUD Code manufactured home shipments data is all the proof that is needed.  That data, combined with anecdotal information from various sources have made it clear that little has occurred from the new class of homes, other than noise from MHI, their allies, and Omaha-Knoxville puppet masters.

YouAskTheQuestionsRecordWithSmarthonePublicStatementsUsefulForExposingCorruptoinCollusioniNsideManufacturedHousingDailyBusinessNewsMHproNews

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MHI CEO Dick Jennison’s Pledge – 500,000 New Manufactured Home Shipments

GSEs’ “Duty To Serve Underserved Markets” Plans

Midwest Manufactured Housing Federation Official Louisville Show Communique to MHProNews

 

Independent National Manufactured Housing Post-Production Association Takes Major Step

Production Decline Continues in November 2018

 

 

 

 

 

 

“What Are We, Chopped Liver?” MHI Member December 2018 Reactions

December 11th, 2018 Comments off

 ClaytonHomes21stVanderbiltManufacuturedHousingInstituteFannieMaeLogoChoppedLiver

 

It should be a given that the upper management of Clayton Homes, and their Arlington, VA based Manufactured Housing Institute (MHI) are in favor of their stated agendas.

 

 

ManufacturedHousingInstituteMHINewClassofHomesDailyBusinessNewsMHProNews

Still from MHI Video, logos added by MHProNews.

 

No sooner than MHI released their self-promotion video, than the industry’s new home shipments data – those nettlesome facts below – indicated that for all of MHI’s claims of millions of readers, their own emailed statement yesterday reflects the opposite results of what they’ve claimed.

Here are the claims, and the evidence, according to MHI.

 ManufacturedHousingInstitutelogoMHILogoMHIVideoStillsMillionsofViewsDailyBusinessNewsMHProNews

 

Here below is a screen capture of MHI/National Community Council (NCC) Vice President Jenny Hodge’s email on the latest data, per MHI.

 ManufacturedHousingInstituteMHILogoOctober2018HUDCodeHomeShipmentsDeclineDailyBusinessNewsMHProNews

What MHI’s own data and claims logically prove is that for all their bluster, new HUD Code manufactured shipments measured by the seasonally adjusted shipment rate (SAAR) – as of the above – are flat for 2018.  Even if the manufactured home industry finishes strong in the final quarter, what actual good has MHI’s promotions done so far?  

But there’s more sobering words from MHI members.

 

“What are We, Chopped Liver?”

An MHI member producer, in a long phone call to MHProNews, argued that the so-called MHI led “new class of homes” makes no sense, because it would have been easier to have simply built state-coded modular homes.

Another MHI producer said that “KEVIN CLAYTON” supported this “new class of homes” plan – which in that professional’s view – harms the interests of the majority of current manufactured housing plants. 

That source said, What are we [meaning the balance and majority of HUD Code manufactured housing production], chopped liver? 

 

The Genesis…

Here’s how a MHI-only member producer explained it in a message to the Daily Business News on MHProNews.

Three years ago I took a group from Fannie Mae through a plant to tour to show what we were building… they were blow away… made you feel they don’t get out much to see what we are building… Surely, good would come from this to obtain better financing on our homes for all [of the manufactured home] industry,” said the message to MHProNews’ tip line.

Fast forward to the roll out of the new class of homes financing…This a slap in the face,” said that production veteran, adding “…what are we chopped liver! Our HUD code is not good enough?

Why [a] 5:12 pitched roof? Many, many factories today will not build that when they have back logs of 3 to 6 months.” He added a laundry list of specs between standard HUD Code production, and the specs that Fannie Mae and Freddie Mac want to see in this Clayton/MHI led “new class of homes,” including, “100% drywall… Why? You cannot see that from the street… let the consumer chose that.”

A number of professionals said that this plan was not only developed by Clayton, it obviously could benefit their new conventional housing subdivisions, which that from has been purchasing in recent years.

Warren Buffett has said that they expect to buy more site building opportunities.

Fannie Mae, Clayton, and MHI – to name but three key organizational players – are attempting to move the industry in a direction that arguably contradicts Kevin Clayton’s own statement from a few years ago.  Some may recall Clayton saying that the industry should not to forget those “that brought you to the dance.”

 

WarrenBuffettKevinClaytonClaytonTinyHouseBerkshireAnnualMeetingDailyBUsinessNewsMHProNews

 

But that new class plan is arguably just what the new GSE connected lending does. It ignores the majority of the industry’s products and consumers in favor of a minority. 

Furthermore, the industry’s HUD Code producers have long been able to build entry-level or residential style products. MHLivingNews articles and videos have made that consumer choice option apparent.

As more than one HUD Code builder proves, you can have residential style homes that are less expensive than these new class of homes will be, and they are proven to attract conventional new home buyers. 

manufacturedhomecollage-entrylevelcapecodmultisectionalsinglesectional-creditmanufacturedhomelivingnewsmhlivingnews

There are markets for each of these styles of homes, and consumers ought to have the ability to chose that home based upon their budget, circumstances, and desires. Builders should be allowed to build whatever the want to as well. That said, what this new class of homes does is bend the system in an artificial way, based upon financing that the GSEs were required to provided under HERA 2008 mandated Duty to Serve to Manufactured Housing. Its an apparent manipulation of the system, and sources say that even if this plan is successful, it will harm many for the benefit of a few. But what if this plan is no more successful than Clayton’s iHouse or iHouse 2.0?  Then, not only time and expense are lost, but the reputation of the industry is harmed too.

For example, award-winning retailer Stan Dye said that half of his sales are to people that previously owned a conventional house.  Isn’t that good enough for Clayton, the GSEs, and MHI?

 

 

Logically, given that

      FHFA,

      the National Association of Realtors,

      HUD’s PD&R

      plus other research shows that the millions of current manufactured homes can and do appreciate,

      where is the logic for creating these new and unproven standards?

 

Consider the Track Record… 

Consider the track record Clayton Homes has in such “innovative” product roll-outs. Our sources at Clayton remind readers that the Clayton’s iHouse and the iHouse 2.0 – which were both rolled out with great fanfare, and got significant media attention – both flopped.

Oops.

 

ihouse Clayton Green-Bridge-Farm-i-House-Chevy-Volt-568x378

Ever wonder whatever happened to the Clayton’s iHouse? Not much, so it was quietly dropped, per sources at Clayton. Will this new class of homes be next?  More to the point, will this Clayton-MHI “new class of homes’ harm the value of the current HUD Code manufactured homes in the process?  Photo Green Bridge Farm, the Clayton iHouse is shown with a Chevy Volt, which is also being cancelled by GM. Oops.

 

Thus far, the GSEs are leaving the vast majority of producers and all other HUD Code manufactured homes essentially out. The indications are that this plan purportedly came from Clayton and is obviously being promoted MHI. Why didn’t they back chattel and other lending for millions of proven HUD code standards homes instead? 

Isn’t backing all HUD Code manufactured homes what the Duty to Serve Manufactured Housing part of the law clearly implied? Where in the Housing and Economic Recovery Act (HERA) of 2008 – which gave us the Duty to Serve (DTS) did it say that the GSEs should compel manufactured housing to create entirely different homes before they get lending?

It’s an outrage, which is why that MHI builder said it is “a slap in face.”

 

 

It Gets Worse

This plan, which MHProNews said last year could be a Trojan Horse, is sadly developing in just that fashion. Because sources say that this plan arguably undermines the acceptance – and thus the value – of millions of existing HUD Code homes.

Who says? A parter and association member in a community operation. He’s not alone.

Beyond complaints about the new class and related GSE lending, one source said that when you factor in the additional costs of building to this new class or homes standards that Clayton-MHI are leading, the consumers who buy them are not going to save money, or get lower payments, even with the GSEs lower interest rate.

Recall that in San Antonio last year, in a room with a few dozen MHI members, Tim Williams of 21st said that the Berkshire Hathaway lender’s wants to make sure that the GSEs don’t take only their top tier credit “traunch.”

Well, it seems that this plan currently avoids taking any loans away from 21st or Vanderbilt. So Tim Williams, former MHI Chairman and still 21st President and CEO, will get his wish.

Put differently, this plan if it fails or succeeds, purportedly harms the bulk of would be and existing consumers. It does so to the benefit one major conglomerate that also does site building. The plan is finding quiet resistance on several fronts from MHI’s own members. 

 InfographicMobileManufacturedHomeManufacturedHousingIndustryFactsDataResearchMobileManufacturedHomeLivingNews

 

But the voices are muted because of the Smoking Gun track record.   You can learn more about that by clicking the linked box, below, for that report.

 

Smoking Gun 3 – Warren Buffett, Kevin Clayton, Clayton Homes, 21st Mortgage Corp Tim Williams – Manufactured Home Lending, Sales Grab?

 

These are some of the explosive comments signaled last week, in the prior report that is linked from the box below.

 

Explosive Comments on Duty to Serve Manufactured Housing Lending from Well Placed Sources

 

Clever Moat Building?

This new class of homes is arguably clever as a tool to eliminate over time more of Berkshire’s competition. By causing some industry firms to invest in a product, it will tend to get those producers ‘dug in’ to continue the plan. They may be following a lead whose Clayton iHouse and iHouse 2.0 both failed. 

But in the meantime, how many thousands of consumers who wanted to refinance 21st Mortgage Corp or Vanderbilt Mortgage and Finance loans – Berkshire Hathaway brands – at a lower interest rate will be left out in the cold? Millions of their HUD Code homes don’t qualify for a program that Congress mandated?  How is that possible, or even sufficient to meet the legal mandates?

Rephrased, this is de facto a head shot against the interests of:

     millions of existing manufactured home homeowners,

     aims at any plants and companies that don’t participate in the plan,

     bending Fannie Mae and Freddie Mac to the will of Berkshire Hathaway, and it was accomplished in closed door meetings that the GSEs, and MHI won’t release the minutes to.

The standards arguably fail in the essence of the Duty to Serve, namely, to provide more lower cost financing for millions of renters.

The American Dream, Arguably Among the Most Profitable, But Least Understood Stories in the USA Today

 

Let the Consumer Choose

The Daily Business News on MHProNews last Saturday said that #HousingChoice should be part of the mantra of the industry’s independents. 

#HousingChoice

Housing Choice, Where Modular, Manufactured, Tiny, Conventional Housing Crisis, MHI and MHARR Intersect

 

Consumers need to be educated to accept what millions have already benefited from. What’s good for consumers is also a strong market for investors, lenders, sellers, communities, suppliers, and others.

Mark Weiss, JD, President and CEO of the Manufactured Housing Association for Regulatory Reform (MHARR) said months ago that the Duty to Serve was a mandate.

 MHARRMarkWeissIfCongressHadMeanttheDutytoServeToBeOptionItWouldNotHaveCalledItADutyDefintionofDutyIsMandatoryResponsibilityDailyBusinessNewsMHProNews

 

Weiss also argued that this roll out of the GSE program was set to benefit only a few companies.

 

ManufacturedHousingAssocRegulatoryReformMHARRMarkWeissDTSFHFA-GSEsGoingtoLargestBusinessesCorpAffiliatesDailyBusinessNewsMHProNews

Collage by MHProNews.

 

It’s not MHI’s VP Jenny Hodge’s fault if new manufactured home shipments are declining. MHI’s president is said to “turn red” when embarrassed or upset. So, how “red” does Richard ‘Dick’ Jennison glow today, after he’s done reading this analysis? 

How red with anger will resident groups become once they figure out that Berkshire Hathaway and MHI – which they arguably dominate – plus the GSEs have ignored them in favor of more expensive housing?

How mad will community owners be if they map out the trend lines, and realize that this plan shafts them too?

Clayton, MHI, and the GSEs won’t formally respond to such concerns. But MHProNews has had tips from ‘inside’ this program, on the GSEs side of the fence.

 

ManufacturedHousingProNewsMHProNewsConfidentialTipsDocumentsNews

To report a news tip, click the image above or send an email to iReportMHNewsTips@mhmsm.com – To help us spot your message in our volume of email, please put the words NEWS TIP in the subject line.

 

As one of those sources experienced in financing told MHProNews, the way this program was developed was “completely backwards.” Instead of listening to the industry, and finding ways to meet the needs, the GSEs dictated standards that were set only for this new class of homes. 

The evidence and the comments from an array of sources suggest that this is no accident. It was an arranged plan. It was rigged from the GSE side, and from the producers side. This plan was unveiled in Las Vegas, we are told that many walked out of the presentation in disgust or protest.

Manufactured Housing Institute “Walk Out,” “Cover Up,” and Shock at their Vegas Event

 

It’s as that MHI producer said, a slap in the face of the industry. And MHI now wants members to open up their checkbooks and renew their association membership for a plan their biggest member logically engineered, aimed at harming their own interests.

 

 

SoTheAssociationMHIIsNotThereFortheIndustryUnlesstheinterestsoftheBigBoysJointheIndustry'sMartyLavinMHIAwardWinnerQuoteMHProNews

MHProNews looks at the facts, considers the sources, and follows the evidence. MHI earlier last year, and for years before, MHI routinely replied promptly to all inquiries. But since we’ve spotlighted the problems and concerns, they’ve gone silent. Why? If the facts are on their side, why not make offer a cogent explanation?

 

It was on a different topic that Marty Lavin said it, but doesn’t it apply here?  As an MHI Producer said, “This program clearly was not “duty to serve.

Based upon the evidence and the track record, MHProNews advises the industry’s members to explore their options with MHARR, MHIdea and NMHCO. More on this in the links below and the days ahead.We Provide, You Decide.” © ## (News, analysis, and commentary.)

NOTICE: Readers have periodically reported that they are getting a better experience when reading MHProNews on the Microsoft Edge, or Apple Safari browser than with Google’s Chrome browser. Chrome reportedly manipulates the content of a page more than the other two browsers.

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SoheylaKovachDailyBusinessNewsMHProNewsMHLivingNewsSubmitted by Soheyla Kovach to the Daily Business News for MHProNews.com. Soheyla is a managing member of LifeStyle Factory Homes, LLC, the parent company to MHProNews, and MHLivingNews.com.

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Housing Choice, Where Modular, Manufactured, Tiny, Conventional Housing Crisis, MHI and MHARR Intersect

December 1st, 2018 Comments off

 

ClaytonHomesLogoManufacturedHousingInstituteLogoAssocRegulatoryReformHousingChoiceWhereModularTinyConventionalHousingCrisisSolutionMeets

Photos from Clayton website, and the logos are the properties of their respective organizations, provided here under fair use guidelines for news media. Text graphics and collage by MHProNews.

It is one of the most controversial issues in the manufactured housing industry today.  Through their apparent power at the Manufactured Housing Institute (MHI), Clayton Homes has backed the notion of a “new class of manufactured homes.”

 

It is a thorny issue, as there are various, divided views on the matter.

 

Certainly, every company has the right and ability to act according to its own perceived interests, within the norms of the law and ethical restraints.

  • If a production company so desires, it can build widget shaped homes and call it a new class of manufactured homes.
  • A firm or organization could say that all new homes should have bull-nosed exterior corners or inverted pyramid shaped roofs in order to get special financing from Fannie Mae or Freddie Mac.
  • Or one could use less esoteric notions, and opt instead for making gutters, downspouts, higher-pitched roofs, and garages available options.

But such details have arguably been incorrectly framed from the start.  Shouldn’t buyers of whatever kind of home they want that meets basic safety, energy, and durability standards be given equal choice for housing in the marketplace, and for financing too?

Rephrased, shouldn’t there be a simple mantra ofhousing choice applied?

The Government Sponsored Enterprises (GSEs) of Fannie Mae and Freddie Mac have a federal legal mandate since 2008 that they somehow managed to dodge for a decade. Now, instead of offering the lower-cost home-only lending that about 80 percent of manufactured home customers select, instead, they provided a program that is only useful for a new, untested, and special kind of HUD Code home?

  • That special kind of home is what Clayton said they wanted, why?
  • And why is that GSE lending pushing a program that is only for land-home loans, which leaves most land-lease communities and the bulk of the retail sales of manufactured homes out in the cold?
  • How do those forced-fits foster housing choice?

 

Housing Choice Should Become Part of the MH Industry’s Mantra

  • Shouldn’t those who want to buy an already federally regulated HUD Code manufactured home be allowed to choose that or any other kind of safe and durable housing they want and are able to purchase?
  • Shouldn’t all housing shoppers who can demonstrate the decades of proven durability of their housing choice be allowed to have the same kind of financing options that conventional housing buyers have been able to access for decades?
  • Shouldn’t home buyers have the right to buy an entry-level or residential-style HUD Code manufactured homes with parity of financing?
  • Isn’t parity of financing an important part of how potentially millions of more price- and payment-sensitive renters can afford to buy a home of their own?
  • So if the clear logic of all of the above are obvious, why did MHI, Fannie Mae, and Freddie Mac hold closed door meetings – refusing to release the minutes of said closed door meeting discussions – which resulted not in more chattel lending, but rather in loans geared only to this so-called, ‘new class of manufactured homes’ that are backed by Clayton?

 

Affirmatively Furthering Fair Housing, a Novel Yet Proven Solution to the Affordable Housing Crisis That Will Create Opportunities, Based Upon Existing Laws

 

Isn’t this new class of homes – and their accompanying Fannie and Freddie lending – just another back-door or oblique way of blocking access to more low-cost lending? Isn’t that effort obviously being led by the Berkshire brands in manufactured housing?  Doesn’t it remind you of the blast-from-the-past, courtesy of 21st Mortgage Corp, that is shown in their letter below?

 

21stMortgageCorpTimWillamsJune112009LetterBerkshireHathawayWarrenBuffettClaytonHomesManufacturedHousingIndustryDailyBusinessNewsMHProNews

Click the image above to download a larger sized version of this 21st Mortgage Corp Letter.

 

Isn’t this new class of homes merely a revised and open version of Smoking Gun 3, where 21st Mortgage cut off lending to thousands of operations that didn’t carry Clayton product?  See the linked report that follows immediately below, plus more related reports further below for added details.

 

Smoking Gun 3 – Warren Buffett, Kevin Clayton, Clayton Homes, 21st Mortgage Corp Tim Williams – Manufactured Home Lending, Sales Grab?

 

We Already Have Had State Coded Modular Homes for Decades, So, Why this ‘New Class’ of HUD Code Homes?

Several voices from various parts of the industry have noted that modular housing already – on paper – had access to the same land/home mortgage lending that conventional housing enjoys.

Indeed, FHA, VA, and USDA already give parity of lending to HUD Code manufactured homes, as well as modular housing, so long as a proper installation and other lending guidelines are met.

Many manufactured home producers already built both “HUDs” and state-coded modular homes.

But HUD Code manufactured homes have widely outsold modular home building for decades. MHI’s own periodic data reflects that point.

When the goal for thousands of land-lease manufactured home communities, hundreds of manufactured home retailing independents, and MHARR has long been to get the GSEs to fully support manufactured homes with personal property loans, where was the logic of MHI pushing ‘behind closed doors’ the use of GSE lending only [???] for this new class of homes?

Hold that thought.

Hold that notion closely, because what the stated goal of MHARR and MHI began with on Duty to Serve seemed on the surface to be the same thing.  That was the apparent intersection, on paper, that virtually everyone in MHVille said they wanted more lending from the GSEs.

But what MHI ended up doing was redirecting their energy to get GSE lending only for their so-called ‘new class of homes.’  Even the new MHI self-defense, self-promotion video makes that reality a key point, as the screen capture from their new video below reflects.

 

LeveragingMomentumCreationNewClassofManufacturedHomesManufacturedHousingInstituteMHILogoDailyBusinessNewsMHProNews600

Screen capture with commentary and MHI’s logo are a collage by MHProNews, which faithfully reflects their “We’re Using Our Momentum Leveraging the Creation of a New Class of Manufactured Homes.” First, what momentum? Second, why the need for a new class of homes? Manufactured housing builders have made residential style homes since at least the 1980s. Buyers could always option in or do on-site whatever they wanted and can afford. It’s therefor a head fake, an apparent ruse that seemingly limits GSE lending to only a tiny sliver of the market that could already be served by modular coded factory-built homes, or by existing residential style HUD Code manufactured homes. This new class of homes is a costly waste of time, save for the fact that it diverts lower-cost financing. Who benefits from that fact?  A monopolist, perhaps?

BloombergShipmentNewManufacturedHomesFactoryBuildRebuildDailyBusinessNewsMHProNews

Third-party to the industry Bloomberg’s shipment data of HUD Code homes reflects that there is a modest recovery, but that the manufactured home industry is still about 75 percent below its 1998 high water mark hit during the last 30 years.

If you want to sell more manufactured homes, this new class of homes is utterly illogical on the surface.  Manufactured housing roared during the 1990s compared to today.  Some claim it was only a sugar-high, based only on bogus lending.  But that claim ignores the reality that those home buyers wanted a manufactured home in the first place. In the mid-to-late 1990s and early 2000s, numerous researchers believed that the EXISTING class of HUD Code manufactured homes was the solution to the affordable housing crisis.

EricBelksyManufacturedHousingIndustryManufacuredHomeManufacturedHousingInstituteResearchDataAffordbleHousingMHProNewsDailyBuisnessNews575

Why did Belsky miss his predicted date? Because it came before Buffett’s entry into MH? See Smoking Gun 3.

So why this need for a new class of homes?  Why not rediscover the proven affordable HUD Code homes, already improved by the Manufactured Housing Improvement Act of 2000?

Two Great Laws Already on the Books NOW,  Can Unlock Billion$ Annually for Manufactured Housing Industry Businesse$, Investor$

 

If you want to encourage the acceptance of HUD Code manufactured homes, then this Clayton/MHI backed ‘new class of homes’ is demonstrably counterproductive on the surface.

Keep in mind that a researcher for the Fannie Mae Foundation some two decades ago already noted back then that manufactured homes merited better lending, placement, zoning, and other treatment. Such facts alone should make it hard for a GSE today to backtrack on their own foundation’s research.  For that report, see the link below.

 

“Why Advocates Need to Rethink Manufactured Home Quality,” Harvard, GSE, Genz, “High Satisfaction”

 

So, this new class of homes makes no sense, unless – unless – there is a hidden or unstated agenda?

  • Is this new class of homes just another monopolistic ploy to expand Berkshire’s Moat in MHVille?
  • And as has been noted previously, isn’t this once more using access to capital or lending to harm the interests of the majority of producers, in favor of one that is also selling site built housing?

 

Machiavellian “Godfather” – Sam Zell, Warren Buffett, Capital, Lending and Crossed Lines in Manufactured Housing

 

The Risk to Existing Manufactured Home Owners

Furthermore, isn’t there an obvious risk that the value of millions of existing manufactured homes will be undermined by this so-called new class of homes?

That isn’t a merely rhetorical question.  Because a senior contact with one of the GSEs admitted to MHProNews that it was a potential hazard.

How would millions of manufactured home owners react to not only not getting GSE chattel lending, but instead, having Clayton-led MHI working in a fashion that undermines the resale values of their homes?  Doesn’t that open the door to a possible class-action lawsuit, against the GSEs, MHI, and Clayton?

An MHI-only member messaged the following to our publisher this week, “You seem to have [a] conceptual IQ that is more important than spelling ability.” That’s nice and clever, but the matter is simply deductive reasoning or logic.

Everything that MHI has done with respect to their so-called new class of homes has been aimed to sideline opposition to it. That isn’t ‘forging consensus,’ is it? Isn’t that silencing opposition or reason-based concerns?

Isn’t what Clayton/Berkshire Hathaway lenders in manufactured housing want is to keep their choke-hold on lower-cost home lending, while promoting their own growing interests in conventional housing, all at the same time?

 

WHERE IS THE LOGIC OF HAVING MANUFACTURED HOMES THAT MAY AS WELL BE MODULARS?

Unless it was to derail GSE lending, and harm independents, all by another slight-of-hand?

All magic tricks are gimmicks, ploys – tricks. The hand is quicker than the eye. Something looks or sounds cool and good, and razzle dazzle presentations are built around it with high-cost consultants who will naturally say what the ones who wrote the check want said. That’s what a state association executive, an MHI member, has told MHProNews.

Some people will always follow a given con, that’s why tricks exist – they work on some people.

This new class of homes is a purported trick, and that is arguably why Richard ‘Dick’ Jennison would not go on with his public presentation at Louisville last January. He apparently feared having to answer questions from the Daily Business News or from members of the audience, who came armed with questions supplied by MHProNews.

 

 

It is also why Fannie Mae arguably cancelled an interview with MHProNews that their media contact had already agreed to do.  What caused that last minute cancellation?  Note that they cancelled only after they knew that among our questions would be some that focused on the genesis of how this new class of homes.

It’s Clayton and MHI, isn’t it?  How else does one explain that BOTH GSEs wanted the same thing?

 

MHARR Exposes GSES’ Failure On Chattel Financing Before Congress

 

What’s Overlooked

The genius of the HUD Code is performance-based standards that superseded other local housing code stipulations. That performance based method keeps housing costs lower for marginal buyers who won’t qualify for $150,000-$225,000 priced housing. Yet the HUD Code achieves that without sacrificing safety or durability.

MostMenAppearnNeverConsideredWhatHouseIsNeedlesslyPoorAllTheirLivesHenryDavidThoreauManufacturedHomeLivingNews

All of the above are HUD Code manufactured homes, built years before the Clayton-MHI backed new class of homes. Newcomers to the website not familiar with modern manufactured homes, learn more by clicking the image above or the link here.

 

There have long been those who argue the HUD vs MOD matter.  Our publisher said years ago that all of factory-built housing should agree not to undermine each other’s products.  Automakers don’t undermine entry-level cars when selling a Rolls Royce. Besides, more expensive modular homes can have their own headaches, as do site built housing, as a new report yesterday underscored.

 

“No Good Deed” – Brad Pitt, Make It Right Foundation Sued for Defective Modular Housing, NBC News, More Video

 

  • Let modular builders do whatever the law allows.
  • Let HUD Code builders build entry-level or more residential-style homes, in any ethical manner that they wish.
  • Ditto for tiny housing, prefab, conventional builders, and so on down the list of legitimate, safe and durable housing providers.

But the Housing and Economic Recovery Act of 2008 (HERA) which gave the Government Sponsored Enterprises (GSEs) of Fannie Mae and Freddie Mac the Duty to Serve Manufactured Housing didn’t mandate any changes to the federal HUD Code.  The GSEs should be providing lending on entry level HUD Code homes, including chattel loans, not just on these pricey new semi-modular housing units.

ManufacturedHousingAssocRegulatoryReformMHARRMarkWeissDTSFHFA-GSEsGoingtoLargestBusinessesCorpAffiliatesDailyBusinessNewsMHProNews

Collage by MHProNews.

 

This new class of homes is arguably a Trojan Horse, a blind alley, a grifters trick.

YouGetMoreOfWhatYouEncourageLessofWhatYouDiscourageMartyLavin

The logic of this statement can be applied to a variety of cases.

 

And sadly, the money trail and evidence – see links below – point to Clayton, 21st and Vanderbilt engineering this via MHI. That means that better lending would be unavailable to the majority of potential manufactured housing customers, as well as to those in communities or private land that may want to refinance their high cost Berkshire Hathaway loans at a lower rate.

 

KennyLipschutzQuotePoorJobOfLobbyinginMHIndustry-postedMHProNews48thMHINCClist

The charade calls for a federal investigation into MHI and the manufactured housing industry’s Berkshire brands, which sources suggest may already be underway.

SoTheAssociationMHIIsNotThereFortheIndustryUnlesstheinterestsoftheBigBoysJointheIndustry'sMartyLavinMHIAwardWinnerQuoteMHProNews

MHProNews looks at the facts, considers the sources, and follows the evidence. MHI earlier last year, and for years before, MHI routinely replied promptly to all inquiries. But since we’ve spotlighted the problems and concerns, they’ve gone silent. Why? If the facts are on their side, why not publicly make a cogent explanation?

 

Housing Choice should become part of the industry’s mantra. For our part, we will spotlight those issues that obscure the common-sense of making manufactured housing another ‘affordable housing choice‘ that home seekers can make with their heads held high, without having to jump through any special and limiting hoops.

 

Duty To Serve, “Complete Waste of Time” per Tim Williams, CEO/21st Mortgage; POTUS Trump, Warren Buffett Insight$

There’s more to come on this in the days ahead, so stay tuned to the only source in manufactured housing trade media that tackles the tough topics with facts, evidence, money trail, reason, and moxie. See the related reports, further below. “We Provide, You Decide.” © ##(News, analysis, and commentary.)

NOTICE: Readers have periodically reported that they are getting a better experience when reading MHProNews on the Microsoft Edge, or Apple Safari browser than with Google’s Chrome browser. Chrome reportedly manipulates the content of a page more than the other two.

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2) To pro-vide a News Tips and/or Commentary, click the link to the left. Please note if comments are on-or-off the record, thank you.

3) Marketing, Web, Video, Consulting, Recruiting and Training Re-sources

SoheylaKovachDailyBusinessNewsMHProNewsMHLivingNewsSubmitted by Soheyla Kovach to the Daily Business News for MHProNews.com. Soheyla is a managing member of LifeStyle Factory Homes, LLC, the parent company to MHProNews, and MHLivingNews.com.

Related Reports:

“Take the MH Advantage Challenge – Can You Tell the Difference?” Fisk of Sarah Edelman, Director of Duty to Serve, Single-Family Mortgage Business for Fannie Mae

GSEs’ “Duty To Serve Underserved Markets” Plans

 

Fannie Mae Touts MH Advantage Program, But Manufactured Housing Association Slams Plan as “Illegitimate,” “Bait and Switch”

Warren Buffett, Charlie Munger, Fannie Mae, Freddie Mac, Berkshire Hathaway Backstory

Machiavellian “Godfather” – Sam Zell, Warren Buffett, Capital, Lending and Crossed Lines in Manufactured Housing

Bloomberg “New Home for $90,000? Manufactured Housing Is Making a Comeback” Reveals MH Media Challenge

 

Secretive “NEW” Class of Manufactured Housing Raises Serious Concerns

FHFA Comments on Duty to Serve Manufactured Home Lending due by Midnight Tonight, with MHProNews Regulatory Comments

November 2nd, 2018 Comments off

 

FHFAlogoCommentsDutytoServeManufacturedHousingFannieMaeDailyBusinessNewsMHProNews

As a reminder to readers, the Federal Housing Finance Agency (FHFA) said the following last month about a request by Fannie Mae to modify their Duty to Serve (DTS) manufactured housing plan.

Here’s the release below, which will be followed by the MHProNews attached comments and related links.

 

FHFANewsReleaseDailyBusinessNewsMHproNews

 

Washington, D.C. – The Federal Housing Finance Agency (FHFA) has announced that it is requesting public input as part of the Agency’s consideration of proposed modifications to Fannie Mae and Freddie Mac’s (the Enterprises) 2018-2020 Underserved Markets Plans (Plans) under the Duty to Serve program. 

The Duty to Serve regulation allows an Enterprise to request to modify its Plan at any time.  However, FHFA must provide a non-objection to a proposed modification for them to become part of an Enterprise’s Plan.  FHFA has determined that public input would be helpful in considering four of Fannie Mae’s twenty-two proposed modifications that would each make a substantial change to the content of its Plan.  Freddie Mac has submitted one modification that FHFA considers to be a modest correction and, as a result, FHFA is not seeking public input on this proposal.  Enterprise technical edits are not subject to public input or FHFA’s Non-Objection.

FHFA requests public input on the proposed modifications to the 2018-2020 Underserved Markets Plan by Nov. 2, 2018 via the dedicated Duty to Serve page on FHFA’s website at www.FHFA.gov/DTS or via mail to FHFA Division of Housing Mission and Goals, Seventh Floor, 400 Seventh Street SW, Washington D.C. 20219. 

About Duty to Serve

FHFA issued a final rule on Dec. 13, 2016 to implement the Duty to Serve provisions mandated by the Housing and Economic Recovery Act of 2008.  The statute requires the Enterprises to serve three specified underserved markets – manufactured housing, affordable housing preservation, and rural housing – by increasing the liquidity of mortgage investments and improving the distribution of investment capital available for mortgage financing for very low-, low-, and moderate-income families in these markets. 

The rule requires each Enterprise to adopt a three-year Underserved Markets Plan detailing the specific objectives and activities they plan to implement to fulfill this mandate.  The activities proposed by the Enterprises will continue to be subject to FHFA review and non-objection to ensure compliance with the Enterprises’ charter acts, safety and soundness standards, and other conservatorship and regulatory requirements.  These Plans went into effect on Jan. 1, 2018. 

Submit Input

##

Our publisher’s regulatory comments on AFFH are linked here, and are to be considered as part of our submission to the FHFA.

Our publishers comments on DTS are linked here.  It includes what should be headline news.

See the related reports, linked further below. “We Provide, You Decide.” © (News, analysis, and commentary.)

(Related Reports are further below. Third-party images and content are provided under fair use guidelines.)

1) To sign up in seconds for our MH Industry leading emailed news updates, click here.

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To see a sample of our emailed news update, click here. To sign up for the factory-built home industry’s #1 headline news, click here or the graphic above.

2) To pro-vide a News Tips and/or Commentary, click the link to the left. Please note if comments are on-or-off the record, thank you.

3) Marketing, Web, Video, Consulting, Recruiting and Training Re-sources

SoheylaKovachDailyBusinessNewsMHProNewsMHLivingNewsSubmitted by Soheyla Kovach to the Daily Business News for MHProNews.com. Soheyla is a managing member of LifeStyle Factory Homes, LLC, the parent company to MHProNews, and MHLivingNews.com.

 

 

 

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Duty to Serve (DTS) Manufactured Housing “Confidential Documents,” Draft and Downloads, FHFA, GSEs