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Insights on Manufactured Housing From Obama White House Federal Archives

June 17th, 2019 No comments

 

InsightsManufacturedHousingFromObamaWhiteHouseFederalArchivesDailyBusinessNewsMHProNews

There is an affordable housing crisis, as HUD Secretary Ben Carson has been stressing for some time.

 

To fully grasp the value of a bipartisan approach to addressing what has arguably been going wrong with the most proven form of affordable housing in America – manufactured homes – it is relevant to look back.  Snapshots and details from prior handling of manufactured homes paint a picture that professionals, advocates, legislators, and others can consider.

During the Obama Administration, there is a federal archive, dubbed: obamawhitehouse.archives.gov.

From that, the following information has been harvested from the “ExpectMore.gov” pages.

In section 1.3 of the information quoted at length, below, is this: “The [Manufactured Housing Improvement] Act provides that the Federal construction and safety standards for manufactured homes pre-empt all state and local building codes. Therefore, no other Federal, state or local program has any authority in this area.”

That may bear repeating. So let’s do so.

The [Manufactured Housing Improvement] Act provides that the Federal construction and safety standards for manufactured homes pre-empt all state and local building codes. Therefore, no other Federal, state or local program has any authority in this area.”

In that context, consider what the Manufactured Housing Association for Regulatory Reform (MHARR) published in their recent letter to HUD Secretary Carson, found as a download from the link below.

 

MHARRCallsHUDSecretaryCarsonEndDiscriminatoryZoningHUDRegulatedManufacturedHomesCommodoreHomesCorpMHARR

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/

 

But there is much more in this assessment from the Obama Archive that merits consideration.  Numbers of concerns that the public at large has held for years are debunked by the federal findings published below.

One of the topics addressed is resale values.  The FHFA and the National Association of Realtors both published research in 2018 that reflect the appreciation of manufactured homes. Note too that this appreciation is occurring despite the lack of a full and proper implementation of the Duty to Serve Manufactured Housing.

The report that follows is summed up as follows, per that same source.

ExpectMoreGovManufacturedHousingStandardsDailyBusinessNewsMHproNews2019-06-17_1205

Having set the table, let’s dive into Obama Administration archive era federal report.

 

Questions/Answers (Detailed Assessment)

Section 1 – Program Purpose & Design
Number Question Answer Score
1.1 Is the program purpose clear?

Explanation: Yes. By establishing and enforcing uniform Federal construction and safety standards, the program’s purpose is to protect the residents of manufactured homes from personal injury, property damage and insurance costs; to advance the quality, durability, safety and affordability of manufactured homes; and to facilitate the availability of affordable manufactured homes and increase homeownership for all Americans.

Evidence: The purposes of program are set forth in the National Manufactured Housing Construction and Safety Standards Act of 1974 as Amended by the Manufactured Housing Improvement Act of 2000 (The Act).

YES 20%
1.2 Does the program address a specific and existing problem, interest, or need?

Explanation: Prior to the Act, manufactured housing historically had lacked the quality, durability and safety of site-built homes. With the enforcement of uniform Federal safety and construction standards, the quality and safety of manufactured homes has significantly improved. Standardized oversight and inspection of design and construction has also reduced the cost and administration to manufacturers that have a common set of standards.

Evidence: Committee hearing testimony from 1974 documented the numerous safety and quality problems with pre-HUD code homes. Studies by the National Fire Protection Association and HUD showing that civilian fire deaths in HUD units built from 1980 to 1996 were 64% lower than for pre-HUD units. Similar reductions for injuries and property damage were also found. HUD standards also reduced complaints of formaldehyde exposure from 1500 to nearly zero in 1984. Newly published HUD report on Hurricane Charley documenting improved performance of manufactured homes built to the wind standards published in 1994 following Hurricane Andrew.

YES 20%
1.3 Is the program designed so that it is not redundant or duplicative of any other Federal, state, local or private effort?

Explanation: The Act provides that the Federal construction and safety standards for manufactured homes pre-empt all state and local building codes. Therefore, no other Federal, state or local program has any authority in this area. The Act also provides that individual states may apply to participate in the enforcement of the program as State Administrative Agencies (SAAs).

Evidence: The preemptive nature of the Act and the regulations requiring HUD approval before a state may participate in the enforcement of the Act.

YES 20%
1.4 Is the program design free of major flaws that would limit the program’s effectiveness or efficiency?

Explanation: The program allows HUD to establish national standards for the construction and safety of manufactured homes, and further allows HUD to act in multiple ways to enforce those standards. HUD can receive information indicating that a serious defect or imminent safety hazard may exist in a class of manufactured homes from the monitoring contractor, an SAA or through a consumer complaint. HUD can then act by investigating the information and issuing a preliminary determination, as can its 38 state SAA partners. In the 12 states without an SAA, only HUD may take such action. A potential flaw in the design of the program is the difficulty ensuring that the In Plant Inspection Agents (IPIAs) who are employed by the production plants remain sufficiently independent and report all violations.

Evidence: No recommendations to fundamentally restructure the program have been made during its 29-year existence; however, the Manufactured Housing Improvement Act of 2000 gave HUD additional authority to design installation standards and a dispute resolution program.

YES 20%
1.5 Is the program design effectively targeted so that resources will address the program’s purpose directly and will reach intended beneficiaries?

Explanation: The program has the ability to target program activities and resources to the agencies and program partners demonstrating the greatest problems. For example, a manufacturer and its in-plant primary inspection agency (IPIA) that demonstrates a higher than average number of failures to conform after a HUD-sponsored audit, or an increased number of failures to conform would be subject to “follow-up” audits. ” As part of these audits, an IPIA operating in a plant, receives a second or third auditing visit from the Department’s contractor to ensure the IPIA and the manufacturer have put in place the necessary correction noted in the Department’s first audit.

Evidence: The monthly report provided by the program’s monitoring contractor lists every follow-up and post-production follow-up audit conducted during the previous month. In 2004, there were XX follow-up audits representing approximately xx% of the HUD’s audit resources.

YES 20%
Section 1 – Program Purpose & Design Score 100%

 

Section 2 – Strategic Planning
Number Question Answer Score
2.1 Does the program have a limited number of specific long-term performance measures that focus on outcomes and meaningfully reflect the purpose of the program?

Explanation: The program has two long-term performance measures reflecting the statutory mandates. For protection of consumers and ensuring the safety of manufactured houses, HUD will measure (and aim to reduce) the number of fire deaths in manufactured homes. In addition, to measure the quality of manufactured housing, HUD will measure the re-sale value of manufactured homes. Another long-term measure HUD has adopted is ensuring new Installation and Dispute Resolution programs are adopted.

Evidence: The number of fire deaths is an excellent outcome measure that tells an important story about the safety of manufactured homes. In addition, it can serve as a proxy for how well other standards are being met. Trends in the re-sale value of homes will also provide some indication of the quality and durability of the homes although other factors may influence this number as well.

YES 11%
2.2 Does the program have ambitious targets and timeframes for its long-term measures?

Explanation: Fire death and re-sale value data will be collected every 5-10 years, and ambitious targets have been set for both. For ensuring establishment of the two new programs, the target is to ensure the provision of installation and dispute resolution services by certified firms and individuals in HUD-administered states by 2008.

Evidence: HUD plans to work with the National Fire Protection Association (www.nfpa.org) to get data every 10 years on the number of fire deaths. HUD aims to reduce the number of fire deaths by 50 percent over next 10 years. Re-sale value of manufactured homes will be collected from industry data.

YES 11%
2.3 Does the program have a limited number of specific annual performance measures that can demonstrate progress toward achieving the program’s long-term goals?

Explanation: HUD’s annual measures support the program’s long-term goals is to assist the Department in reaching its Strategic Goal to Embrace High Standards of Ethics, Management and Accountability to Ensure Program Compliance by enhancing monitoring and enforcement. HUD is working to develop efficiency measures for their program. They must work to identify administrative costs needed to perform follow-up audits, correct homes, or pursue enforcement cases.

Evidence: Three annual measures are or will be reported: 1. The annual performance measure for protecting consumers is the number of investigations and enforcement cases pursued each year. 2. HUD also measures the number of homes corrected as a result of federal investigations and enforcement actions. 3. HUD recently decided to count the number of plants requiring follow-up audits to measure how well its inspection processes work.

YES 11%
2.4 Does the program have baselines and ambitious targets for its annual measures?

Explanation: HUD sets ambitious targets for each of its three annual measures. They aim to improve performance between 5 and 10 percent each year for each measure.

Evidence: HUD aims to increase the number of enforcement cases and homes corrected as a result of those cases by at least ten percent each year from the baseline of 34 enforcement cases in 2003. The baselines for number of homes corrected and number of plants requiring audits are still being developed.

YES 11%
2.5 Do all partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) commit to and work toward the annual and/or long-term goals of the program?

Explanation: In protecting consumers through investigations and enforcement, the program relies on a variety of cooperating parties. Many of the Department’s investigations and enforcement actions stem from the initial investigations undertaken by the 38 state administrative agencies who have cooperative agreements with the federal program, the 17 in-plant primary inspection agencies (IPIAs), and 7 design approval primary inspection agencies (DAPIAs). States and their appointed agencies have worked with HUD program staff to ensure that states develop installation and dispute resolution program regulations to allow the maximum number of states to administer their own programs. HUD will continue to work with stakeholders on new measures adopted.

Evidence: The Department also works in cooperation with the other federal agencies to identify potential non-compliance, and in initiating investigations and enforcement by the Department. HUD also partners with the National Fire Protection Association. To ensure establishment of the two new programs in all states, federal program staff have worked with the following states in the state efforts to put in place the necessary elements to administer state installation and/or dispute resolution programs by January 2006: DE, GA, ID, IA, IN, KS, LA, NY, OH, OK, PA, TN, WA, and WI. HUD has also shared information with the two national industry groups, the 0Manufactured Housing Institute (MHI) and the Manufactured Housing Association for Regulatory Reform (MHARR), assisting them in their efforts to encourage and assist states to establish state-based manufactured housing installation and dispute resolution programs.

YES 11%
2.6 Are independent evaluations of sufficient scope and quality conducted on a regular basis or as needed to support program improvements and evaluate effectiveness and relevance to the problem, interest, or need?

Explanation: Prior to undertaking most construction and safety standards revisions of a substantial nature, the Department undertakes independent research to support the program improvements. The program has relied on a variety of independent evaluations to support program improvements and evaluate effectiveness and relevance to the program area. However, most evaluations to date have focused on specific aspects of safety standards rather than the program as a whole. HUD next plans to work with PD&R to develop a comprehensive study that examines the entire program offices’ effectiveness.

Evidence: Examples of recent research include a March 2005 report from the Institute for Building Technology and Safety entitled “An Assessment of Damage to Manufactured Homes Caused by Hurricane Charley.” Fire research also supported the Smoke Alarm Rule in 2002, the final rule for formaldehyde emissions published in 1984, the upgraded wind requirements in the final rule published in 1994, and the upgraded energy requirements final rule published in 1993. Independent evaluation of fire losses in manufactured homes identified trends supporting the actions taken in the final rule. In 1998-1999 the Department commissioned the National Institute of Standards and Technology to evaluate the adequacy and reliability of the current requirements for smoke alarms, which had been in the federal manufactured home construction and safety standards since 1976.

YES 11%
2.7 Are Budget requests explicitly tied to accomplishment of the annual and long-term performance goals, and are the resource needs presented in a complete and transparent manner in the program’s budget?

Explanation: The level of appropriations is key to the Department’s oversight and auditing of the design approval primary inspection agencies. With reduced appropriation, the federal manufactured housing program would reduce its oversight of these three groups, providing increased opportunity for poor performance by manufacturers, and an increased number of failures to conform in completed homes.

Evidence: The Office of Manufactured Housing Programs outlines its budget justifications as required by OMB, with a Performance Measurement Table and the Performance Indicator outlined in the Annual Performance Plan. Appropriated funds are provided in that format. The 2005 Congressional Justification is provided as required by the Department. In the FY 2005 justification, the cost categories totaled the requested amount for the appropriation of $13 million and are broken out into the following categories: Payments to states; Salaries; Contract for monitoring primary inspection agencies and states; Contract for consensus committee administering organization; Other contracts; Contract for installation inspection and enforcement; and Contract for dispute resolution enforcement.

YES 11%
2.8 Has the program taken meaningful steps to correct its strategic planning deficiencies?

Explanation: The Office of Manufactured Housing and Standards conducts annual, monthly, and weekly meetings that identify deficiencies and ensure achievement of long-term goals.

Evidence: The Office of Manufactured Housing and Standards conducts an annual strategic planning meeting, followed by monthly meetings with staff and the contractor responsible for sustaining compliance of homes to the construction and safety standards; monthly meetings with staff and the Administering Organization contractor responsible for maximizing cooperation with the MHCC; weekly meetings with the FHA Commissioner on FHA matters; and planned monthly meetings with staff and the contractor responsible for overseeing the federal installation program in 2006.

YES 11%
2.RG1 Are all regulations issued by the program/agency necessary to meet the stated goals of the program, and do all regulations clearly indicate how the rules contribute to achievement of the goals?

Explanation: All regulations currently being drafted and published as proposed rules are tied to goals established by the 2000 Act, in addition to the statutory goal of establishing the installation and dispute resolution programs.

Evidence: The first proposed rule necessary to establish one of the two mandated programs was published on April 26, 2005. The other proposed rules include a draft proposed rule to establish the Installation Program and the Dispute Resolution Program. Another proposed rule for which the public comment period has ended and the Department is preparing a final rule, is a proposed rule to revise the federal construction and safety standards. In addition to those mandated by statute, there are regulatory actions proposed by the MHCC which the program office is required by statute to act. These include a rule to define and allow on-site completion of manufactured homes. Other regulatory actions include a proposed rule to correct inequities created in a regulation revising the payment of fees to states, and a rule in draft to increase the fee amount from $39.

YES 11%
Section 2 – Strategic Planning Score 100%

 

Section 3 – Program Management
Number Question Answer Score
3.1 Does the agency regularly collect timely and credible performance information, including information from key program partners, and use it to manage the program and improve performance?

Explanation: The agency collects performance information and uses it to improve performance. The program office relies on staff and contractor oversight of the performance of the in-plant primary inspection agencies (IPIAs), design approval primary inspection agencies (DAPIAs), and state administrative agencies (SAAs) through annual performance reviews. Inspectors spend approximately 300 days each year in manufacturing plants overseeing the monitoring work of the IPIAs, receiving for record and random review 18,000 design pages of manufactured homes, and undertaking 22 reviews of state administrative agency performance. They submit checklist assessments to HUD annually. Based on this information, the program office identifies program weaknesses and requires increased HUD monitoring, or plans of corrective action. Information on follow-up audits and homes completed is also gathered from these actors.

Evidence: Based on audits or visits to plants, the program office may shift resources to increasing monitoring of poorly performing partners. IPIAs may receive follow-up audits, DAPIAs may receive increased monitoring, and SAAs may receive on-site visits. The program’s contractor has collected this information for over 20 years, providing valuable baseline information for the performance of program partners. For example, an increased number of audit findings in plants in Florida (in which the State of Florida serves as the IPIA) caused the federal program to order a higher than usual number of follow-up audits on the Florida production lines. This combined with a static number of failures to conform during the follow-up audits keyed the federal program to target technical assistance and intervene early.

YES 9%
3.2 Are Federal managers and program partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) held accountable for cost, schedule and performance results?

Explanation: The program managers and partners are accountable for achieving performance goals. The Manufactured Housing Program Administrator reports to the Assistant Secretary for Housing and the Secretary, and in the Office of General Counsel, the Assistant General Counsel for the Division of Compliance. For program partners, the performance of IPIAs, DAPIAs and SAAs are reviewed annually, based on regular audits throughout the year.

Evidence: All state administrative agencies (SAAs) and primary inspection agencies (PIAs) are held accountable for cost, schedule and performance results through oversight of their own work within manufacturing plants throughout the year, which is summarized in an annual review of performance. These third parties are paid directly from the manufacturers, with their costs, schedules, and performance controlled by market forces for the private PIAs, and by state regulation for the state PIAs. The work of the program contractor, conducting the PIA audits on behalf of the federal program, is monitored by program office staff, ensuring the work is completed within budget, on schedule and meets performance results.

YES 9%
3.3 Are funds (Federal and partners’) obligated in a timely manner and spent for the intended purpose?

Explanation: Funds are obligated in a timely manner. For investigations and enforcement the funds are expended through the cost of salaries, and payments to the states – a primary partner in identifying cases for investigation and enforcement. For establishment of the two new programs the primary program expense is for salaries, cost of the Administering Organization for the MHCC, and upcoming costs of procurements for establishing the programs. Each year all funds are obligated (if not yet expended) prior to the end of the fiscal year

Evidence: The annual appropriations Act provides authority to collect user fees for an amount up to but not exceeding the appropriated amount. The FY 2005 appropriation was for no more than $13 million. The regulations mandate the formula by which the incoming fees are shared with the state administrative agencies (SAAs). Congressional budget requests outline seven categories of how the funds are to be targeted. Fees are tallied and transferred to the expenditure account on a monthly basis, limiting all expenditures to current funds on-hand. Fee income and expenditure is recorded by HUD’s budget office. Contractor costs are monitored by the GTR and DCAA audits. The payments to states are made based on formula, and state program costs are monitored within the appropriate state as mandated by state law or regulation.

YES 9%
3.4 Does the program have procedures (e.g. competitive sourcing/cost comparisons, IT improvements, appropriate incentives) to measure and achieve efficiencies and cost effectiveness in program execution?

Explanation: The program cannot receive credit for this because it is still developing an efficiency measure. However, procedures to use competitive sourcing and contracting are authorized in the language of the 1974 statute, and have assisted the program in achieving efficiencies in program execution. Additional authorities to contract for services were part of the 2000 Act. Competitive sourcing and procurement of monitoring services assist in protecting consumers through investigations and enforcement (See 3.1 response).

Evidence: The Manufactured Housing Program has accomplished the above with what is currently a workforce of 10 professional and 3 administrative staff, and only one fee increase in over 15 years. In addition, since 2000, total program income has fallen (due to a fall in production and related income) 30 percent. This has required the program to reduce on-site, design and state monitoring by 60 percent. These resource commitments are to be compared to the total number of manufactured homes in the U.S., over 8 million.

NO 0%
3.5 Does the program collaborate and coordinate effectively with related programs?

Explanation: The fundamental basis of the Federal Manufactured Housing Program is collaboration and coordination with state and private programs. While responsible for ensuring the quality, safety and durability of manufactured homes, the foundation of the program is for the federal office to oversee the work of manufacturers through partnerships with states and private organizations overseeing or investigating the quality of the manufacturers’ work.

Evidence: For enforcement and investigation the federal program relies on the efforts of ten state primary inspection agencies (PIAs), six private primary inspection agencies, and 38 state administrative agencies (SAAs), as outlined in the program regulations. The program office also collects information from FHA, HUD’s Office of Policy Development and Research, the Federal Emergency Management Agency, Consumer Product Safety Commission, and the U.S. Fire Administration to identify specific cases for further investigation and enforcement, or to analyze trends in safety in manufactured homes. A recent example of effective collaboration with CPSC, was a CPSC product recall requiring notification of homeowners and correction of a defective gas water heater valve, a process required in 24 CFR Part 3282.404. In this case, CPSC recalled approximately 35,000 gas water heaters nationwide manufactured by the firm “State Water Heaters.”

YES 9%
3.6 Does the program use strong financial management practices?

Explanation: The Manufactured Housing Program displays strong financial practices. The monitoring contractor accounts for the collection of all manufactured housing fees, calculates payments due to the SAAs, and produces the paperwork necessary to authorize these payments. This not for profit organization is chosen in a competitive procurement process. The contractor’s financial management has been audited in accordance with the OMB Circular A-129 requirements. Over 29 years, the same or a related organization with the same management leadership, has fully accounted for HUD’s accurate payments to its state partners.

Evidence: The program has never been over budget. The Federal Manufactured Housing Program has never been identified by the Office of Inspector General or GAO as requiring an audit for oversight, nor have its contractors. There have been no Congressional investigations or hearings. The primary contractor working with this program has completed independent audits consistently returned with no action items.

YES 9%
3.7 Has the program taken meaningful steps to address its management deficiencies?

Explanation: The Administrator now holds a monthly enforcement meeting with program and OGC staff, and with the assistance of monitoring contractor staff, identifies potential enforcement cases.

Evidence: The most recent deficiencies were identified in 2002 when the recently appointed Administrator noted no existing process to generate investigations or enforcement actions. This led to setting a performance goal in this area. The Administrator initiated a monthly meeting with selected program staff and staff of the Office of the Office of General Counsel to identify potential enforcement cases for investigation. The appointment of the Administrator also facilitated smoother action in carrying out the steps necessary to reach the long-term goal of establishing the two new programs mandated by the 2000 Act.

YES 9%
3.RG1 Did the program seek and take into account the views of all affected parties (e.g., consumers; large and small businesses; State, local and tribal governments; beneficiaries; and the general public) when developing significant regulations?

Explanation: The Department is undertaking a large amount of regulatory development to complete the statutory mandates of the Manufactured Housing Improvement Act of 2000. This includes the preparation and publication of proposed rules for the Model Manufactured Home Installation Standards, the Manufactured Housing Installation Program Regulations, and the Manufactured Housing Dispute Resolution Program. In several instances, the 2000 Act mandates coordination with the Manufactured Housing Consensus Committee (MHCC). In other instances, the Department has published an Advance Notice of Proposed Rulemaking, soliciting public comment prior to drafting the proposed rule, and has solicited comment from the PIAs and SAAs.

Evidence: In the instance of the Model Manufactured Home Installation Standards, the statute mandated that the proposal come from the Manufactured Housing Consensus Committee, comprised of 21 persons representing Users, Producers and General Interest. HUD also discusses with PIAs and SAAs the other proposed rules currently under consideration by the Department and the MHCC, for their information and feedback prior to proposed rule publication.

YES 9%
3.RG2 Did the program prepare adequate regulatory impact analyses if required by Executive Order 12866, regulatory flexibility analyses if required by the Regulatory Flexibility Act and SBREFA, and cost-benefit analyses if required under the Unfunded Mandates Reform Act; and did those analyses comply with OMB guidelines?

Explanation: All rules are reviewed internally at HUD by designated offices, and externally at the appropriate agencies for their cost impact, regulatory impact, regulatory flexibility, and small business impact. Of the draft or completed proposed rules, only the Model Manufactured Home Installation Standards has completed OMB review. The program office received limited comments from OMB, all of which were incorporated into the proposed rule. No comments were received from any other agency (See response to 4.1).

Evidence: Previous program rules published within the past five years have also complied, including the Smoke Detector Rule and the proposed revisions to the Construction and Safety Standards. The cost-benefit impact of this rule was estimated to be between $9 and $11 million, with approximately 30 lives saved.

YES 9%
3.RG3 Does the program systematically review its current regulations to ensure consistency among all regulations in accomplishing program goals?

Explanation: The program office has introduced, and worked with the MHCC in its proposed revisions to regulations to ensure consistency among all regulations, when drafting new or revised regulations. The MHCC is charged by statute to propose revisions to the Manufactured Housing Construction and Safety Standards at least once every two years, requiring a regular review of the design and construction regulations.

Evidence: The MHCC is developing proposed revisions to Subpart I of 24 CFR Part 3282, “Consumer Complaint Handling and Remedial Actions” and program and counsel staff have worked extensively with the MHCC in the development of these potential revisions and to identify current regulations in 24 CFR Part 3280 and 3282 which need revision as a result of changes to Subpart I in 3282. The program office proposed revisions to 24 CFR Part 3282.15 “On-Site Completion of Homes” to simplify the process of installing homes at the site, and 24 CFR Part 3284, “Manufactured Housing Program Fee”, and has identified specific sections of Parts 3280 and 3282 which need revision.

YES 9%
3.RG4 Are the regulations designed to achieve program goals, to the extent practicable, by maximizing the net benefits of its regulatory activity?

Explanation: The proposed regulations mandated by the 2000 Act are designed to achieve the program goals stated in Response 1.1 (Program Purpose), and are designed to reflect current practices in the private sector for home inspection and approval. However, cost-benefit analyses have not been completed for two key rules – Installation and Dispute Resolution standards.

Evidence: The proposed regulations are the result of actions mandated by the statute such as the proposed rules for the Model Installation Standards, the Dispute Resolution Program, or the Installation Program, actions to assist the program in reaching its goals such as Part 3282.15 “On-Site Completion of Homes” or the clarification and simplification of the “Consumer Complaint Handling and Remedial Actions” being developed by the Department and the MHCC.

NO 0%
Section 3 – Program Management Score 82%

 

Section 4 – Program Results/Accountability
Number Question Answer Score
4.1 Has the program demonstrated adequate progress in achieving its long-term performance goals?

Explanation: The target and timeframe for investigations and enforcement is an increase of investigations and enforcement cases by 100 percent from 2003 to 2008. Data for other key long-term outcomes on fire deaths and resale value has yet to be collected. Fire deaths correspondes to the long-term goal of ensuring housing is safe, while re-sale value provides a proxy for the durability of the home.

Evidence: HUD is within the proposed timeframe to meet targets for enforcements and number of homes corrected. HUD plans to work with stakeholders to gather data to show progress towad its other long term measures that it is working to collect baseline data for, including fire deaths and resale value of manufactured homes.

SMALL EXTENT 6%
4.2 Does the program (including program partners) achieve its annual performance goals?

Explanation: The program reports its performance in the The FY 2002, 2003, and 2004 Performance and Accountability Reports and has largely met its target for the Annual Performance Plan (APP). The program has made progress on investigations and enforcement by reaching its annual targets for the number of enforcement cases, and by beginning to track the number of homeowners positively impacted by the investigations and actions. HUD is still gathering data to show progress in reducing the number of follow-up audits.

Evidence: The Performance and Accountability Reports describe the progress of the program office in its efforts to reach the statutory goals outlined in each fiscal year’s Annual Performance Plan. The Program Office and OGC’s Office of Compliance maintain a tracking system indicating the number of enforcement cases opened and closed in each calendar year.

LARGE EXTENT 12%
4.3 Does the program demonstrate improved efficiencies or cost effectiveness in achieving program goals each year?

Explanation: While the program does not currently have an efficiency measure, it can demonstrate some improved efficiencies and cost effectiveness. For example, the number of program staff from FY 2003 to FY 2005 has decreased as has the real dollar value the program commits to its monitoring contractor; however the program has been able to continue establishing the two new programs and increase the number of enforcement cases.

Evidence: To sustain compliance of manufactured homes to the federal standard the program currently operates with a staff capacity of ten professional and three clerical staff. Recent staff reductions have resulted in somewhat lower program accomplishments, but the program continues to meet most long-term targets. The primary goal of the program with the reduced staff is the sustained compliance of manufactured homes to the federal standard while making progress to meet the two long-term targets by 2008.

SMALL EXTENT 6%
4.4 Does the performance of this program compare favorably to other programs, including government, private, etc., with similar purpose and goals?

Explanation: While comparisons are difficult, other agencies also protect consumers through investigations and enforcement. For example, two other federal programs with similar legal foundations are the National Highway Transportation Safety Program, and the Consumer Product Safety Commission. Other similar programs include State or local codes and corresponding regulatory programs for factory-built housing, designed and built according to state or local code, such as modular housing. Another program with a similar purpose and goal would be a code and regulatory program for site-built housing. These are designed and constructed to state or locally enforced standards and are constructed on-site. The fee charged by any state or oversight agency for every transportable “modular” unit, built in a factory varies according to state or local requirements. In 2002 at the time the federal manufactured housing fee was $21.00 per transportable unit, state modular housing fees in 29 states averaged $51.00 per transportable unit.

Evidence: HUD’s manufactured housing is most efficient and cost effective as compared to the two benchmarking industries. The regulatory fees and number and cost of construction inspections are low. Design approvals take less time, and the preemptive nature of the program removes the cost of a single builder constructing in more than one jurisdiction being required to be knowledgeable of more than one building code. The quality gap that previously existed between manufactured housing and modular and site-built has reduced significantly. [Still awaiting data to support this claim.] The remaining gap in quality is determined primarily by market forces and consumer needs, rather than the ability of the industry to provide higher quality housing.

LARGE EXTENT 12%
4.5 Do independent evaluations of sufficient scope and quality indicate that the program is effective and achieving results?

Explanation: These evaluations include the recently released study on the performance of manufactured homes during the multiple-hurricane period in Florida in the summer of 2004: “An Assessment of Damage to Manufactured Homes Caused by Hurricane Charley” – March 2005. Each evaluation confirmed the effectiveness of the federal program in continuing to achieve the required level of safety and standards conformance with the current level of staff and resources. HUD plans to work with HUD’s Office of Policy Development and Research to design an evaluation of its program office’s effectiveness.

Evidence: One of the primary measurements of effectiveness and results is in the sustained compliance of manufactured homes to the federal standards. The most recent is in the just-released study entitled, “An Assessment of Damage to Manufactured Homes Caused by Hurricane Charley” – March 2005, conducted by an integrated team of staff from HUD’s manufactured housing office, and its contractor, and an independent contractor experienced in post-disaster housing damage assessments. The report concluded that manufactured homes produced after July 13, 1994 when the Department’s current wind load requirements were implemented, performed significantly better than pre-1994 homes at a statistically significant high level of confidence. Further, pre-HUD Code homes were much more severely damaged than newer (post 1976) HUD Code units at a high confidence level. The State of Florida Installer Licensing Program also issued a report in August 2004 after Hurricane Charley, and in September 2004 after Hurricane Ivan. Both Florida reports noted the performance of homes and installation systems, and the “admirable” performance of manufactured homes built since HUD’s 1994 stricter construction requirements in high wind zone areas.

LARGE EXTENT 12%
4.RG1 Were programmatic goals (and benefits) achieved at the least incremental societal cost and did the program maximize net benefits?

Explanation: Three primary indicators best measure how programmatic goals have been achieved at least societal cost. One is the comparison of the federal government’s overall added cost to the product, with the federal fee measuring less than one quarter of one percent of the overall cost of the average manufactured home unit ($39 compared to $45,000 average cost of a house). HUD has also completed several specific cost analyses if new or revised construction and safety standards that show societal benefits.

Evidence: The program analyzed past enforcement actions, which showed that 90 percent of the enforcement actions undertaken by the program and its counsel over the past three years have been actions of settlement, and not pursued to judgment. These actions have resulted in corrections being made to all existing homes and designs, to the greatest benefit of those at risk. For the additional smoke alarm requirements added through the Final Rule published March 19, 2002, the average cost impact was estimated to be $40 per unit, and estimated to result in 30 lives saved annually. The number of complaints related to problems with formaldehyde exposure after improving the standard decreased from 1,500 to approximately five complaints per year.

YES 10%
Section 4 – Program Results/Accountability Score 58%

 

This report is found on the webpage, linked here.

This should be viewed in the context of the broader related reports, linked below the bylines and notices.

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

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

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

HUDSecretaryBenCarsonSpeechManufacturedHomesManufacturedHousingActiveIngredientMedicationStrongerAmericaMHLivingNews

https://www.manufacturedhomelivingnews.com/hud-secretary-ben-carson-speech-on-manufactured-homes-manufactured-housingactive-ingredientmedicationfor-a-stronger-america/

 

 

 

 

 

 

 

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

June 8th, 2019 No comments

 

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?

 

 

2018-10-03_1018ManufacturedHousingInstituteHILogoCavcoFleetwoodPalmHarborFannieMaeFreddieMacLogoDailyBusinessNEwsMHProNEws

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.

MarkWeissDTSQuoteManufacturedHousingAssocRegulatoryReformMHARRDailyBusinessNewsMHproNews

ManufacturedHousingInstitutePhotoOpportunitiesDailyBusinessNewsMHProNews

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?

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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.

 

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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.

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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.

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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)

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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

 

 

 

 

 

Key to Unlocking Door for More Manufactured Home Sales, Professor Lisa Tyler’s Valuable Research

May 31st, 2019 Comments off

 

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Let’s begin with a factoid from Zillow. Only eight percent – 8% – of housing shoppers consider a manufactured home. To the savvy marketer, investor, or other industry professionals — that is the challenge and the opportunity in disguise.

 

Turned on it’s head, accepting Zillow’s data means that 92 percent of the population isn’t even thinking about living in a manufactured home. Stating the obvious can bring clarity. Keep in mind that every retail sale is a local sale. A home sold at retail is going to a specific home site, or into a specific lot, or to a specific piece of property or land-lease community.

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Only 8 percent of housing shoppers considered a mobile or manufactured home, and many of those did not buy one. That’s both a challenge, but also an opportunity in disguise for those who have a sales and marketing system that deals with that reality. This graphic makes several points that savvy manufactured housing marketing and sales agents must be aware of, and include as part of an integrated marketing and sales plan.

 

So, to increase sales, one doesn’t have to convince the nation or the world that manufactured homes are better than is generally believed.  Rather, what must be accomplished is convince more people in a specific market area that manufactured homes are the best kept secret in affordable housing.

Hold those thoughts.

At its core, the above is an educational process. But it is a specific kind of education that can very much relate to marketing and selling. Hold those thoughts too, because we will return to them soon.

Rephrased, Manufactured Homes are misunderstood. Marketers, sales professionals, brokers, managers, and business owners must grapple with that reality.

The reasons for the misunderstandings are relevant, but we will leap over that for now, and point to Lisa Tyler, Ph.D., and the thesis of her important doctoral dissertation, entitled “Examining Community Attitudes Toward Manufactured Housing.”

For an article like this, one must drill down to core concepts. Let’s zero in on this gem from Professor Tyler. “Despite evidence that disproved misconceptions…negative stereotypes continued to influence local governments to impose regulatory restrictions on this type of [manufactured, factory-built] housing.”

Keep in mind that in order to obtain a Ph.D – the highest academic degree in her field – there are certain standards that must be met. Tyler had to go through peer reviewed examination, and the work she cited had to have occurred within five years of the time she produced her doctoral dissertation. That too had to be peer reviewed research.

Put differently, now Dr. Tyler wasn’t just a giving a bunch of nice sounding opinions.

That’s precisely what someone wants that is trying to debunk myths or mistaken notions.  It is third party information that millions of Americans need to be exposed to, or in the case of most independent professionals, thousands of people in your market(s) have to be effectively exposed to a process that ‘educates’ them as part of engaging them.

 

Cui Bono? Who Benefits?

People benefit or not from information. People can also benefit or not from misinformation. As a top executive in manufactured housing told this writer, “I’m ready for infowars.”

Beliefs don’t exist in a vacuum. Beliefs are formed one story at a time, until a picture emerges in someone’s mind. While some people have the background, training, or mental discipline to question commonly held thinking, not all do. That’s not a slam on those who don’t. Rather, that’s yet another opportunity in disguise.  What others in your area are unwilling to do – if you and your team do it – can honorably set you apart.

As an owner, manager, leasing, or sales professional, your primary concern is the reality of your business, and the market(s) your business serves. You want more of that 92 percent who don’t think about manufactured homes to do exactly that, and to do that with you at your location(s).

Consider the following.

Your prospective customer, in order to complete a sale must meet a few conditions.

  • They have to have the economic and financial ability to buy.
  • They have to have the willingness to buy.
  • They have to be able to explain their purchase in a satisfactory way to their friends and neighbors.

There is more. But those are essentials.  A Clayton Homes professional told MHProNews that cancellations of deals after they are started is a significant issue.  Clayton isn’t alone in that, “buyers remorse” happens to others too.

There are a variety of ways to summarize learning. My friend, author, and colleague Tim Connors, CSP, summed up sales and marketing education with these 4 phases.

  • Awareness.
  • Understanding.
  • Integration.
  • Mastery.

A front line sales person may be aware of some idea – this article, for instance – can be the start of awareness. But awareness of issues and opportunities without a deeper understanding, an integrated method for taking a shopper from skepticism to enthusiastic buyer, and that must be done enough to eventually master the method.

Is Connor alone in that thinking? Hardly.

Consider what Barry Noffsinger said to sum that up in the acronym, ADKAR.

 

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Zig Ziglar believed something similar too. That’s why he stressed that hearing something once was not enough. Ziglar believed that motivation and training had to be routinely done to be enduring.

 

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After years of research and real world experience, we’ve learned that properly educating – coaching, training – a sales team member or front-line manager is motivational. Rephrased, it’s not about merely emotional cheerleading. Rather, we provide the instruction that yields the confidence that allows the professional to BE motivated, instead of FEELING – briefly – motivated.  But something similar must happen for prospects too.

 

Repetitive inputs are critical.

Let’s apply that to manufactured housing.

Intentionally or not, Americans are fed a steady diet of misinformation and terminology that is demeaning about manufactured homes. A certain level of correct information must be available for them. There must also be a logical way to disabuse a prospect from years of what amounts to negative programming.

Articles and videos can help with that, but one must also have a front line professional(s) that have been properly forged in the methods of walking a prospect from curiosity to completing a sale with a customer who is satisfied enough to tell their friends. Then that new home buyer must be able to defend their decision too.

Given the reality of all the negativity around manufactured homes, that being dealt with in the marketing and sales process is huge.

 

Third Party vs. Your Words

You saying something may or may not be believed. But some third party that doesn’t benefit saying something is far more likely to be believed. That’s why those who mistakenly think they can post an article on their own retail center, community, factory, or lenders’ website is not likely to work with most people. That’s like you telling them, and the seller is doubted by most prospects.

So there must be a third-party resource that has experts that compliments the work of a front line sales or leasing professional and their manager(s).

Then, that third-party resource ideally likewise must cite third-party experts, such as Dr. Lisa Tyler.

Manufactured Home Living News (MHLivingNews) is that third-party platform. Seeing the need, we began that project several years ago. There are few things more compelling than watching and listening to happy home owners, combined with the research that uses experts and evidence to debunk misconceptions.  For example, Tyler’s work – and that of numbers of others – can be access in the article linked below.

 

 

Let’s use an analogy. There is positive and negative energy present in electricity. Without both positive and negative protons and electrons, there is no power.  Our society has for some reason been conditioned to avoid whatever appears negative. Nonsense. Without embracing and dealing with both the positive and negative, there will only be very limited results.  David Ogilvy was famous – as a marketer. Grasping nettles means you grasp the problems.  Nettles sting, but they are also medicinal. It’s a great metaphor for what our industry needs.

 

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It seems controversial to some to question authority. Frankly, that’s a traditional role of media, including good trade media. For example, Kim Komando has built a large audience of tech lovers, but she has at times taken on vexing topics like the dark sides of Facebook. Understood properly, that helps her credibility, it doesn’t harm it.  Our credibility has arguably been helped, not harmed, by taking on vexing issues inside manufactured housing. That doesn’t mean that everyone likes every article or topic. Nor is that necessary.  We make people think, which is the first step to problem solving and goal attainment.

Dr. Tyler didn’t just write about manufactured homes. She owned one for several years. This I know, because she told me. Lisa was kind enough to mention me in her acknowledgements to her dissertation. While I encouraged her work, because it is important, she did the doing. She deserves the glory.

Dr. Tyler is one of several experts that have studied the subject of manufactured housing. She is pro-industry. Her research is useful.  Which begs the question. Why is her work not mentioned on the Manufactured Housing Institute’s (MHI) website?

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Or why is Eric Belsky’s work also missing from MHI’s website? Recall that in years gone by, MHI quite correctly used to refer to then Harvard University’s Joint Center for Housing Studies (JCHS) Belsky in their brochures and literature. If he was good enough before, why not now? Rephrased, Belsky was dropped by MHI. Why?

 

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Scholastica ‘Gay’ Cororaton did perhaps the most useful third party research on manufactured housing in 2018. Cororaton works for the National Association of Realtors (NAR) as a Certified Business Economist (CBE). She’s missing the morning from MHI’s website too. Yet Cororaton cited not only myself in her first footnote, but also someone from MHI. It’s not like MHI doesn’t know about her.

 

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Furthermore, each of these subjects have been brought to MHI’s attention directly by me, and indirectly – per our sources – to others.

Last but not least today, there is HUD Secretary Carson, and prior HUD Secretary Julian Castro. Carson’s speech to MHI is still missing from MHI’s website, yet that was now three weeks ago.

 

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There is no mention of this video, posted below, where Carson on a national business news channel raised manufactured housing’s profile in a positive way. The interview begins with a discussion of 3D printed housing, but ends with favorable points about manufactured homes.

 

 

Nor is there any mention whatsoever of Julian Castro and his video. That’s really odd, as it was an MHI vice president who provided that video to me in the first place.

 

 

Rephrased, MHI has the Castro video, because they arranged for it. Yet, it is missing from their own website?

Manufactured housing – as Dr. Carson (GOP) and 2020 presidential hopeful Julian Castro (D) both have said – is an important part of the solution to the affordable housing crisis. MHI knows that, so why have they failed to provide third party validation to their arguments for the industry?

Let’s be clear. Staffs’ jobs at a trade association are to carry out the board of directors instructions.  At MHI that’s the MHI Executive Committee.

These can’t all be oversights, can they?

So whatever one might attribute as the motivation for these failures by MHI, the fact remains they are doing some things, that are clearly insufficient, or manufactured housing wouldn’t be misunderstood, and new home shipments would not be sliding 7 straight months year-over-year during an affordable housing crisis. It is an apt example are what Mark Weiss, JD, President and CEO of the Manufactured Housing Association for Regulatory Reform (MHARR) called “The Illusion of Motion.”

 

The Solution Begins at the Local Level

You and I can’t fix MHI, nor do we need to do so. But we must grasp the reality of MHI, in order to advance in your local market(s) efforts.

When one grasps that the negative energy around manufactured housing often flows from ‘big boy’ MHI member companies, those who aren’t black hat ‘big boys’ should differentiate themselves from the rest. You and your firm – to unlock your full potential – must be seen by the public as a white hat company in an industry that housing shoppers have been led to believe is led by black hat operations.

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We know the importance of emotions, because we have them too. But the Creator gave us a mind to think with, not just emotions that if unchecked can carry us away, a bit like dead fish floating down stream.

The correct combination of mind-opening marketing, combined with front line sales professionals supported by management that grasps these realities can walk an individual prospect one step at a time from curiosity into happy home ownership.

That’s best done one-on-one. By using a mind opening methodology, by teaching a staff to do the same, what you end up with is the widest array of prospects. As the sales team increasingly ‘gets it,’ they’ll sell an ever greater percentage and total number of prospects.

This method is honest, not manipulative. The customer is respected, not tricked. At the end of the process, they are now ‘in the know,’ which makes then feel empowered not diminished. They become the opposite of what too many think of as ‘trailer trash.’

This take effort, but it pays.

It is also something that requires nothing from the national association, or anyone other than you and your team’s connecting with our existing and proven resources. Which brings us back to Dr. Tyler.

She aptly made the point that it was community attitudes that are where the issue lies.  More fundamentally, it is with individuals, who in sufficient numbers influence or make up a community.

The positive, profitable change – once the dynamics are understood and navigated – can be addressed at the local level. That is where all sales take place. That’s something you and your team can successfully accomplish in a profitable, honorable, and sustainable fashion. To learn more, click one of the tabs – or check out the Related Reports, below the byline and notices.

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This should not be misunderstood. Good videos, good photos and websites are useful. But if that was all that is needed, the industry’s sales would be 10 times larger than they are today. Clearly, education of the home buying public is missing. That’s what the Zillow research cited above reflects.

Denying reality may be a mild form of insanity. The opposite of that is to deal with what is real.  That’s this morning’s manufactured housing “Industry News, Tips, and Views Pros Can Use,” © where “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.)

LATonyKovachQuoteManufacturedHousingIndustryWontReachPotentialAddresscoreIssuesArtificallyholdingitback466By L.A. “Tony” Kovach – for MHProNews.com.

Tony is the multiple award-winning managing member of LifeStyle Factory Homes, LLC, the parent company to MHProNews, and MHLivingNews.com.

Office 863-213-4090 |Connect on LinkedIn:
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What is Marketing? What is Selling? Succeeding with Manufactured Homes in Your Local Marketplace(s)

 

Ultimate, Proven Contrarian Investing – Ethical vs. Unethical, Legal vs Illegal Manufactured Housing Industry Strategies

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“Game On” – “Fighting Discriminatory Zoning” “Moral Obligation” Fix “Worsening Nightmare” – State Associations Entering Spotlight

Bipartisan Praise for Manufactured Housing, What’s Next

April 26th, 2019 Comments off

 

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Wheat and chaff. Let’s give credit where it is due. These two video clips were obtained by the Manufactured Housing Institute (MHI). That’s good. They represent bipartisan praise for manufactured homes as an important part of the solution to the affordable housing crisis. That’s good too.

 

One might wonder why these videos aren’t on YouTube, or why they aren’t being prominently promoted. After all, former HUD Secretary Julian Castro is now a Democratic contender for their party’s nomination for president in 2020. Secretary Ben Carson, MD, is a former 2020 presidential contender. Both men are respected by their respective political party’s.

 

 

But these video statements – freely made by the top person of the federal agency that has primary oversight over federally regulated HUD Code manufactured homes are useful.

 

 

So too was the bipartisan statement made at the state level by a committee that studied manufactured homes. See that report, linked below.

 

 

 

The positive facts about manufactured housing are well known in industry circles. Some third-party, academic-style research in 2018 likewise amounted to praise of the industry. Perhaps the most notable was the research done recently was by the National Association of Realtors, Certified Business Economist (CBE), Scholastica ‘Gay’ Cororaton. So why has MHI not posted that on their website?

 

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As this and other fact-checks reveals, there’s an increasingly evident pattern of failures to properly promote manufactured housing that one can discern at MHI. They question becomes, why? They know about the Cororaton’s useful NAR research. The Arlington, VA based trade group also knows about those two videos, and numbers of others like them.

A trade group sharing such informational/educational material that corrects or clarifies facts about our industry’s housing products and services with industry members is fine. But it isn’t enough.

 

It’s the general public that needs convincing.

 

It is also local public officials that need to be made aware of letters like the one linked here from HUD to a local jurisdiction, reminding them that they could not supersede federal authority.

MHProNews research has identified numerous third-party reports that are useful for referencing the proven value of federally preemptive HUD Code manufactured housing.  That research dates back for over 20 years.

The Manufactured Housing Association for Regulatory Reform (MHARR) website has a clearly stated aim to achieve industry growth. They have identified specific issues that are holding the industry’s retailers, communities, and developers back from achieving far higher levels of new HUD Code home sales.  A search of their website reveals several references to Enhanced Preemption. See composite screen capture below, from earlier today.  They are a production, not post-production, trade association representing independent builders of federally regulated manufactured homes.

 

 

EnhancedPreemptionManufacturedHousingAssociationRegulatoryReform4-26-2019ManufacturedHomesMHProNews

 

So why is it that MHI as an ‘umbrella’ association that claims to represent “all segments of factory-built housing” – which clearly includes post-production interests – has no mention at all of enhanced preemption.  This search was repeated today, which had the same result as on the previous date shown.

 

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Both sources with MHI, and MHI’s outside counsel, have stated that they monitor our website. MHI leaders have been asked directly about this issue. No changes. Given the issues the industry faces on zoning and placement, why are they allowing one of the best arguments to go unused?

 

When NIMBY and other factors are causing the industry to face pushback, solution oriented professionals must ask, what are the steps that can be taken to address these issues?

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Certainly, part of it is educational.  Local jurisdictions that are taking an anti-affordable housing, or anti-manufactured home stance need to be made aware of the economic harm that their posture causes.  The negative aspect of that is where “Seattle is Dying” and related reports come in.

 

 

That is also where “Fear” comes in, because that report originally published here, and update on MHLivingNews at the linked text-image box below lays out the economic benefits from fostering more affordable housing, all by references to third-party research.

 

 

The above are association work, or the work of a business/investor willing to tackle that locally, knowing the upside profit potential from having done so.

Finally, it could also – at least in theory – be the grounds for a civil rights case by impacted citizens.  In such a scenario, such as exists in Bryan, TX, recovery of legal fees plus damages could be a potential outcome.

 

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This was part of third-party, university level research. It is one of several such reports over the years. Why are these reports not prominently on the MHI website?http://www.mhmarketingsalesmanagement.com/blogs/daily-business-news/wp-content/uploads/2019/04/CommunityGuideToFactoryBuiltHousingHUDPDRManufacturedHousingModularHomeMHProNews2001.pdf

CommunityGuideFactoryBuiltHousingInfillDevelopingModularHousingManufacturedHomes2001HUDPDRMHProNews

This was part of third-party, university level research. It is one of several such reports over the years. Why are these reports not prominently on the MHI website?http://www.mhmarketingsalesmanagement.com/blogs/daily-business-news/wp-content/uploads/2019/04/CommunityGuideToFactoryBuiltHousingHUDPDRManufacturedHousingModularHomeMHProNews2001.pdf

MHI in an oblique response to our repeatedly raised concerns has taken to showing photos of their staff or elected leaders with public officials.  What good are those examples of access actually doing the industry?  Are they not in fact a striking case of MHI failing to use that access in furtherance of the interests of independents who want to see new HUD Code manufactured home sales growth?

 

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What practical impact have these prior photo ops actually resulted in, other than photos that MHI uses to impress people with their access? Why not use that access to get HUD to make enhanced preemption a routinely enforced reality?

 

What’s next from MHI? When will they do their self-proclaimed job?  When will they use their self-proclaimed clout?  Photo opportunities alone are meaningless, perhaps even embarrassing, if they don’t ultimately result in timely solutions to issues such as the full implementation of Duty to Serve, or correcting the zoning/placement issues that exist from coast-to-coast.

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That’s this edition 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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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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2020 Contender Presidential Julian Castro, Obama Era HUD Secretary Announces Exploratory Run

December 13th, 2018 Comments off

HUDSecretaryJulianCastroManufacturedHousingIndustryDailyBusinessNewsMHproNews

 

The Associated Press (AP) is reporting that “Former Obama housing chief Julian Castro says he’s taking a step toward a possible White House campaign in 2020 by forming a presidential exploratory committee,” with an announced decision set for Jan. 12, 2019.

 

Castro is said to be the second formally announced Democratic contender, following Maryland Rep. John Delaney.

JulianCastroWikiDailyBusinessNewsMHproNEws

One of the points that makes this candidacy of interest to manufactured housing professionals is that Castro was former President Obama’s Secretary of Housing and Urban Development (HUD).

 

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Full Measure’s Sharyl Attiksson’s media bias chart is useful in sorting out the agendas behind various headlines and news sources. 

 

The MSNBC video clip below clearly reflects that Castro is taking positions very much in keeping with the leftward tilt of the Democratic party.

 

A video by the HUD Secretary praising manufactured housing is linked below.

 

 

Of course, verbal praise is one thing, but the actual deeds are often another.

Castro may also remind manufactured housing professionals about the painful memory of Pamela Danner’s selection to head up the Office of Manufactured Housing Programs (OMHP).

 

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Pam Danner, JD, HUD Code former Manufactured Housing Program Administrator, credit, MHProNews.

That in turn, should remind industry professionals that the Manufactured Housing Institute (MHI) reportedly turned on their agreement to advance the candidacy of Victor DeRose.  De Rose was the “consensus candidate” formerly agreed to by MHI and the Manufactured Housing Institute (MHI) and the Manufactured Housing Association for Regulatory Reform (MHARR).  But an MHI ‘insider’ advanced Danner – per sources – and while MHI’s President Richard ‘Dick’ Jennison was purportedly “livid,” and “apologetic,” MHI in fact did only fig leaf posturing, while states struggled under the Obama- and Castro-era Danner appointment at OMHP.

It is also a reminder that MHI PAC Chairman, Nathan Smith, is a high profile Democrat, who if history holds, will promote whomever their party nominates. So, supporting someone like former Secretary Castro would arguably be no problem for Smith, and thus likely, for the rest of MHI.

 

Nathan & Mary Lee Chance Smith, Leaders in ‘Anti-Trump Resistance,’ Manufactured Housing Impact?

 

It is one of several #NettlesomeThings about MHI that as 2018 winds down, and 2019 looms ahead, the industry’s professionals must soberly consider.  For a detailed review of issues, see the linked report access in the box immediately below, as well as more insights from the Related Reports, further below. That’s tonight’s “News through the lens of manufactured homes, and factory-built housing.” © where  “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.

Related Reports: Click the Boxes Below to Read More...

Greener, Stylish Manufactured Homes – Hidden Facts in the Washington Post Manufactured Housing Narrative

 

Understanding the News as Business, and Manufactured Housing

“Check Your Facts,” “Follow the Money” – Journalist Sharyl Attkisson, Fake News, MHVille Takeaways

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

 

 

 

 

Yes, Thankfully There’s Times Manufactured Homes Earn Bipartisan Praise in Washington, D.C. Metro

November 22nd, 2018 Comments off

YesThankfullyTheresTimesManufacturedHomesEarnBipartisanPraiseinWashingtonDCMetroDailyBusinessNewsMHProNews

A new article on Manufactured Home Living News (MHLivingNews) points out praise across the left-right partisan divide in favor of modern manufactured homes.

 

That same new Thanksgiving Day report also pulls together elements from both national trade associations that are based in or near Washington, D.C.

In that lighter holiday mood, and as positive as is reasonably possible spirit, you can see the report, linked below.

 

Giving Thanks for Mobile Homes, Manufactured Homes, Classic “Mobile Home Parks” and Manufactured Home Communities

For another Thanksgiving report, thankful for the independents, who along with others, made manufactured housing great, see the related reports, further below.  From all of us to all of you, happy Thanksgiving. ##We Provide, You Decide.” © ## (News, analysis, and commentary.)

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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.

 

Related Reports:

Giving Thanks for Mobile Homes, Manufactured Homes, Classic “Mobile Home Parks” and Manufactured Home Communities

Giving Thanks for Manufactured Housing Independents, Applauding “MHIdea!”

What’s the Truth About Thanksgiving in MHVille?

 

Candidate: Beef Up Manufactured Home Community Inspections

May 17th, 2017 Comments off
creditsanantoinioexpressnews-postedtothedailybusinessnewsmhpronewsmhlivingnews

Oak Hollow Community. Credit: San Antonio Express.

In San Antonio, Texas, District 8 councilman and mayoral hopeful Ron Nirenberg is making a push to change the municipal code.

According to My San Antonio, Nirenberg, fresh off an endorsement from former HUD Secretary Julian Castro, is looking to beef up the city’s inspections of manufactured home communities, and the City Council Neighborhoods and Livability Committee approved his proposal earlier this week.

The city will now conduct public meetings with various stakeholders, to determine exactly how to amend the municipal code that regulates communities.

Additional changes could include enabling the city to levy higher fines or pursue civil penalties against mobile home park [sic] owners who repeatedly violate the code,” said Michael Shannon, the city’s interim director of development services.

Currently, the city can only press criminal charges against community owners.

This is an effort to address what I think is a gap in policy, to make sure we have some proactive inspections,” said Nirenberg.

creditsanantoniocurrent-postedtothedailybusinessnewsmhpronewsmhlivingnews

Cleanup at Oak Hollow. Credit: San Antonio Current.

Nirenberg says that he proposed the measure after the city ordered the relocation of families in the Oak Hollow Mobile Home Park, which is in his district, of overflowing septic tanks and other poor conditions. The Daily Business News originally covered that story here.

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Sewage Line at Oak Hollow. Credit: KABB.

In this case, Joe Mangione, owner of Oak Hollow Mobile Home Park, has been served a cease and desist order by the city. The order tells him to stop lying to his “tenants.”

I’ve lived there four years, and then my sisters lived there for at least 15 years before that. It’s always smelled like this, I just never knew where it came from,” said one of the residents.

I mostly keep [my daughters] indoors now.

Upon investigation, the city found raw sewage leaking from decrepit septic tanks and directly into the park’s soil, including one leak directly underneath a tenant’s home. The resident was forced to avoid one of the rooms due to the smell.

The city determined that 12 of the homes were in such bad shape that the health department was legally bound to alert those living in Oak Hollow that they would need to move out of their home and into hotel rooms, paid for by the city, until the landlord addressed the problem.

Current law states that manufactured home communities must register with the San Antonio Department of Heath and are subject to inspection, but Nirenberg says that sites are not routinely inspected, and often only go to communities after receiving a complaint.

CandidateProposestoBeefUpManufacturedHomeCommunityInspectionscreditMySanAntonio-postedtothedailybusinessnewsmhpronewsmhlivingnews

Julian Castro and Ron Nirenberg take a selfie. Credit: My San Antonio.

My concern was that we prevent the kind of issue we saw at Oak Hollow,” said Nirenberg.

We know if mobile home parks [sic] fly under the radar, there’s really no guarantee of that.”

Nirenberg says his hope is that increasing inspections are part of a larger package of reforms to the city code.

His goal is to establish communications and assistant protocols in the event another Oak Hollow situation arises.

In the case of Oak Hollow, there was an extended displacement, where the residents were placed in hotels, and there was only a short period of assistance for them to do so,” said Nirenberg.

According to Deputy City Attorney Joe Nino, the city filed a suit against Oak Hollow in December and is trying to work out a settlement.

A for sale sign is posted on the property,” said Nino.

 

The Julian Castro Effect 

julian-castro-housing-urban-development-hud-secretary-bloombergtv-businessweek=credits-posted-daily-business-news-mhpronews-com-

Credit: Bloomberg.

In December 2015, Castro praised the manufactured home industry, saying in part “a good home is a powerful platform to spark progress in people’s lives. It connects families to the communities that surround them, and it lays the foundation for their health, their happiness and their future success.

That’s why we call HUD, ‘The Department of Opportunity.’ And that’s the importance of the work we do together.

The United States faces an affordable housing crisis. And manufactured homes serve as a vital solution for folks of modest means, particularly in rural areas.”

The full commentary from Castro is linked here. ##

 

(Image credits are as shown above, and when provided by third parties, are shared under fair use guidelines.)

 

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RC Williams, MHProNews.

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

 

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HUD Announces Record $1.9 Billion in Grants to “End Homelessness”

December 26th, 2016 Comments off
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Credit: HUD.

On December 20th, the Department of Housing an Urban Development (HUD) announced that it has awarded a record $1.95 billion to numerous homeless assistance programs across the U.S., including Puerto Rico, Guam, and the U.S. Virgin Islands.

As part of the Obama Administration’s effort to prevent and end homelessness, the U.S. Department of Housing and Urban Development today awarded a record $1.95 billion in grants to nearly 7,600 homeless assistance programs across throughout the nation, including Puerto Rico, Guam, and the U.S. Virgin Islands,” HUD said in a prepared statement.

The awards, know as “Continuum of Care” grants, are intended to “prevent and end homelessness.

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Julian Castro. Official photo.

Per CNS News, HUD is urging states to spend the grant money on their “highest-performing local programs that have proven most effective” in reducing homelessness.

Today marks another critical investment in support of those working each and every day to house and serve our most vulnerable neighbors,” said HUD Secretary Julian Castro.

We know how to end homelessness and will continue to encourage our local partners to use the latest evidence to achieve success. These grants support proven strategies to end homelessness once and for all.

Among the states receiving grants, California will get the largest share a total of $352,946,617 for 933 local homeless-assistance projects, followed by New York with $195,920,284 for 621 projects, Illinois $104,862,190 for 416 projects, and Pennsylvania $100,357,941 for 515 projects.

Among the states receiving the least in grants are: Wyoming, $291,611 for 5 projects, South Dakota with $1,264,095 for 10 projects and North Dakota receives $1,903,991 for 20 projects.

DrBenCarsonNominatedHUDSecretaryAskIfSameFundsWhatValueCreated-postedManufacturedHousingIndustryDailyBusinessNewsMHProNews-

Screen capture from the 6 page document by Dr. Carson, posted on a commentary linked here. Carson has been named by the Trump transition team as the president-elect’s pick to lead HUD, which is the primary regulatory agency for the HUD Code manufactured housing program. Will Dr. Carson work to merge, for example, DOE’s energy program back into HUD? The document download linked from the commentary above offer clues.

The Solution for Homelessness, Hiding in Plain Sight

As Daily Business News readers – and forward looking manufactured housing professionals and investors know –  manufactured homes provide a quality, affordable solution to the housing challenges that the nation faces.

A growing number of mainstream media, as well as federal public officials and politicos in both major parties agree on that fact, as is reflected in the Julian Castro video posted below.

MHI and MHARR have both welcomed incoming HUD Secretary Dr. Ben Carson.

Dr. Carson has been invited in an open letter by our publisher to better understand the potential for manufactured housing to save on federal budgets, while offering free market solutions that can cut homelessness and increase independence rather than dependence.

With the U.S. Census Bureau reporting an average manufactured home price of $66,000 (see 2016 manufactured housing fast facts report, linked here), the manufactured housing industry could provide 29,545 homes with the $1.95 billion in grants that HUD has made available. Leveraging that same sum could raise that by a factor of 10 to 20. Using a more modest model manufactured home than the median or average size would further increase the potential impact the total numbers served by such government programs.

Over time, following that pattern, federal and any matching state/local spending could be cut, while dramatically improving the lives of each of those touched.

The solution to affordable quality housing is hiding in plain sight. ##

(Image credits are as shown above.)

rcwilliams-writer75x75manufacturedhousingindustrymhpronews

RC Williams, for Daily Business News, MHProNews.

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

Affordable Housing Included in $500k HUD Grant to Oklahoma City

August 1st, 2016 Comments off

building under conversion to housing naked philly  credit postedDailyBusinessNews-MHPronewsThrough the Hope VI Main Street Program, the U. S. Department of Housing and Urban Development (HUD) has awarded Bartlesville, Oklahoma a $500,000 grant to redevelop a 90-year-old abandoned church campus into a mixed-use development which will include affordable housing.

The collaboration of Bartlesville Redevelopment Trust Authority (BRTA), Main Street Bartlesville (MSB), Washington County Affordable Housing Coalition (WCAHC), and Ross Group/New Leaf Development (RGNL Development) will also include retail space and hospitality space in addition to the 32 residential units, as portal.hud.gov informs MHProNews.

The Main Street Program reflects a new urbanism approach to downtown revitalization that emphasizes walkable space, access to transportation, health care and day care facilities, arts venues, a university, grocery and pharmacy, public library, childrens’ amusement park and playground, et. al., very inclusive like a village.

HUD Secretary Julián Castro said, “In communities like Bartlesville, a grant like this can not only provide much-needed affordable housing, but also a boost of economic activity. Walkable neighborhoods, with access to jobs and groceries, are sustainable neighborhoods where folks can succeed. HUD is proud to be a partner in rebuilding an area like Bartlesville.”

Bartlesville received a grant last year to redevelop a hospital in order to crate more affordable housing.

HUD’s thrust is to repurpose old commercial buildings as rent and tax producing affordable housing. ##

(Photo credit:nakedphilly–building being converted to housing)

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

MHI’s Dick Jennison, CFPB’s Richard Cordray on Manufactured Home Loan Regulations

March 17th, 2016 Comments off

dodd_frank___bloombergbusinessweek___creditWhile governmental officials, industry leaders and financial executives agree that manufactured housing (MH) is a solution to the problem of affordable housing in the nation—Julian Castro, head of the U. S. Department of Housing and Urban Affairs (HUD) calls MH a “vital solution for folks of modest means”–regulations imposed by the CFPB have resulted in access to credit being denied those who would have qualified, prior to the establishment of CFPB.

Marty Lavin, an expert on MH lending, adds that reduces sales and resale values. “We’re taking away the free choice of people without good cause,” he said.

The snowball effect resulting from the implementation of Dodd-Frank leaves many would be buyers and sellers of less expensive MH unable to acquire financing, which in turn prevents those who want a more expensive MH unable to sell their older, but useable MH–except for cash–which reduces overall sales.

Says Dick Jennison, president and CEO of the Manufactured Housing Institute, “We need to remove the shackles that the Dodd-Frank Act and the CFPB rules have placed upon our industry.Barney Frank said the legislation that bears his name was never intended to have the deleterious effect on MH that it does.

Furthermore, as pressreleaserocket points out, the loss of new MH sales reduces industry employment in production, retail, moving, insurance, etc.

Noting that people who are shut out of buying a manufactured home because of lending restrictions often have to opt for rental living, Sen. Bob Corker (R-Tenn.), tells MHProNews, “They are ending up paying more for rental housing than they would end up paying by actually purchasing a lower-cost home.”

To which the CFPB’s Dir. Cordray might say, as he once did, “That doesn’t sound optimal from anybody’s standpoint… We should be thinking about whether the (lending) thresholds are exactly right.”

Lending restrictions on manufactured housing not only hurt the economy—they can endanger the health and safety of those of the most modest means by preventing them from purchasing a safe home to raise a family.

For a video of views from across the MH spectrum, click here. ##

(Image credit: bloombergbusinessweek)

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