Posts Tagged ‘hmda’

Sobering Federal Report on Manufactured Housing Lending – Retailers, Communities, Producers, and Finance Companies – Take Note

January 17th, 2019 Comments off



The rebranded Bureau of Consumer Financial Protection – formerly the CFPB, now the BCFP – has produced a January 2019 report that contains new data regarding manufactured housing lending.


There are over 200 pages. We’ll simplify that for busy readers.

MHProNews will hereby provide the entire document here as a download, while give readers like yourself the most relevant pull-quotes for manufactured housing.

After the quoted sections and tables, the Daily Business News on MHProNews will provide a brief and relevant analysis for manufactured home industry professionals, investors, affordable housing advocates, plus public elected or appointed officials.  The graphics are from the name of the report, that included the following quoted items.




7.2.1 Data and methods



This analysis uses the non-public HMDA data described in Chapter 1.350 In the context of this chapter, any reference to “lender(s)” or “creditor(s)” only refers to HMDA reporting lenders. Estimates of small lenders in this analysis are not the complete universe of mortgage originators. The Bureau estimates that there are over 4,000 depository institutions which originate mortgages but are not HMDA reporters. Most, if not all, of HMDA non-reporters would qualify as small creditors due to their small size…


…2016. Fewer lenders, ‘consolidation.’

Table 38 reports mortgage originations by small and non-small creditors in rural counties.366 Among small creditors, the share of total originations occurring in rural areas is much larger than for non-small creditors. This appears to be consistent with the higher likelihood that small creditors operate only or predominantly in rural or underserved areas compared to non-small creditors. The 2016a columns suggests that without the 2016 threshold amendments, the rural share of small creditor originations would have stayed the same instead of decreasing to 21…


Foonote 366) The Bureau publishes a yearly list of rural and underserved counties that are exempt from certain regulatory r equ irements of the Truth in Lending A ct. Bureau of Con sumer Fin. Prot., Rural and Underserved Counties List, available at /policy-compliance/guidance/implementation-guidance/rural-andu n derserved-counties-list/ (last v isited Dec. 31, 2018) (for the current and previous y ear’s lists).


…percent in 2016 with the amendments. The 2016 amendments did however increase the share of small creditors operating in rural areas due to being more inclusive of larger lenders. The amendments in 20

Table 39 reports manufactured housing mortgage originations by small and non-small creditors. Manufactured housing loans make up a larger share of small lenders’ originations compared to non-small lenders. Similar to rural loan originations, these patterns are consistent with small creditors being more likely to provide access to mortgage credit for manufactured housing compared to larger creditors although the share or manufactured originations that make up a small creditor’s lending has been declining since 2012.



What Does This Reveal for MHPros, Policy Wonks, and Advocates?

Lenders in the manufactured housing space has declined during the period reported.

Put differently, manufactured lending has contracted, just as the number of retailers have shrunk.  Here is the key line.

“…small creditor’s lending has been declining since 2012.”

This has occurred in the aftermath of Warren Buffett led Berkshire Hathaway’s acquisition of Clayton Homes, other producers, retailers, and associated lenders, notably 21st Mortgage Corp and Vanderbilt Mortgage and Finance (VMF).

While making noise for several years about making the Duty to Serve by the Government Sponsored Enterprises (GSE) a reality, what the BCFP data reflects is that the opposite is taking place.

Manufactured housing professionals, investors, and advocates? This is another wake up call.  For more details, see the related reports, linked below the byline and notices.  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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Data Confirms Dodd-Frank Regulations Impede Manufactured Home Loans

September 28th, 2015 Comments off

MH two story for sale   greg vote getty images creditThe Manufactured Housing Institute (MHI) informs MHProNews that data regarding lending at 7,000 financial institutions and covering nearly 10 million mortgage applications and six million loan originations reveals manufactured home lenders are not making HOEPA (Home Ownership and Equity Protection Act) loans because of the increased liability and burdensome rules of smaller loans, like many MH loans.

Opponents of the Preserving Access to Manufactured Housing Act have been arguing that consumers will lose the HOEPA high cost protection if the legislation passes, when in fact lenders simply are not making loans and are leaving the market and consumers are the ones hurt the most since Dodd-Frank took effect.

A report from the Federal Reserve 2014 Home Mortgage Disclosure Act (HMDA) data describes the decrease in MH loans, saying it is “a precipitous drop in the number of loans originated in 2014 at the HOEPA price threshold, whereas, for 2013 – before the new threshold rules took effect – no such discontinuity was evident. This pattern suggests that HOEPA discouraged lending above the price thresholds.

Many retirees, veterans and working families are unable to obtain financing to purchase manufactured homes; and those who may want to sell their MH see their home values decline because potential buyers cannot find appropriate financing as lenders no longer offer suitable loan products, resulting in home owners selling for cash at a substantially reduced price.

These federal government policies are destroying family net worth and harming the ability of credit-worthy families to achieve the American dream of homeownership,” says MHI.

The Preserving Access to Manufactured Housing Act (H. R. 650), which has already passed the House of Representatives, will restore financing options for MH buyers and provide core consumer protections against predatory lending.

In the Senate, the measure (S. 682) is included in a larger financial regulatory relief package that was passed by the Senate Banking Committee (S. 1484) and the Senate Appropriations Committee.

The MHI urges you to contact your members of Congress and remind them of the importance to their constituents of the Preserving Access to Manufactured Housing Act. Click here to send them an email. ##

(Photo credit: Getty Images/Greg Vote–manufactured home for sale)

matthew-silver-daily-business-news-mhpronews-comArticle submitted by Matthew J. Silver to Daily Business News-MHProNews.