Posts Tagged ‘PhD’

Wall Street, Lesli Gooch – Manufactured Housing Institute EVP – Penetrating Scotsman Guide Interview Analysis

January 26th, 2019 Comments off



Timely information combined with money can move stocks and markets. Information may be legally or illegally used, as the growing storm clouds over Cavco Industries (CVCO) concerning certain trades by Joe Stegmayer and Cavco reminded the manufactured home industry and its investors.  But note that Stegmayer and Cavco are not directly tied into today’s analysis, though they will be the focus of a looming report.


There was an interview reported this past week by the Scotsman Guide with the Manufactured Housing Institute (MHI) Executive Vice President (EVP) Lesli Gooch, Ph.D. That publication has quoted MHI previously.

Before examining Gooch’s comments and their timing, one should pause and do a brief refresher on the award-winning Oliver Stone movie, Wall Street.  Some selected quotes from Wikipedia will serve to tee up the ball, by conveying plot-lines that convey fictional but still useful concepts.  Each bullet is a quote from the link here.

     Bud Fox is a junior stockbroker at Jackson Steinem & Co. in New York City. He wants to work with his hero, Gordon Gekko, a legendary Wall Street player.

     Bud provides him [Gecko] some inside information about Bluestar Airlines, which he has learned in a casual conversation with his father, Carl, leader of the company’s maintenance workers union.

     …Gekko offers Bud another chance, and tells him to spy on British CEO Sir Lawrence Wildman and discern Wildman’s next move. Bud learns that Wildman is making a bid for a steel company. Through Bud’s spying, Gekko makes money, and Wildman is forced to buy Gekko’s shares to complete his takeover.

     …Bud is promoted as a result of the large commission fees he is bringing in and is given a corner office with a view. He continues to maximize inside information and use friends as straw buyers to provide more income for him and Gekko. Unknown to Bud, several of his trades attract the attention of the Securities and Exchange Commission.

     …Bud devises a plan to drive up Bluestar’s stock before manipulating it back down…” 


The MH Evening Market Report 

Every evening for several years, the Daily Business News on MHProNews does a closing market recap of specific manufactured housing industry connected stocks after the closing bell. What years of observations have yielded helped forge an evolving evening market report. Every business news show or website is premised in part on the notion that news stories, data, headlines, and insights often move one or more stocks, or even the broader markets.

For balance, MHProNews uses bullets from CNN Money and Fox Business, to allow for the media’s evident left-right divide. We use closing market data from CNN, Yahoo, and Bloomberg too.



MHProNews looks at issues from a wide variety of perspectives.


That a mere statement can move stocks and/or the broader markets is beyond question. For example:

Warren Buffett, Jeff Bezos, and Jaime Dimon made a public announcement in 2017 on the day of President of the United States (POTUS) Donald J. Trump’s State of the Union (SOTU) Address. Healthcare stocks, and much of rest of the markets dropped that day, as an apparent result.  Prior to that, stocks had enjoyed a long, steady rise.

Words and ideas apparently matter to Wall Street and investors. Who speaks those words matters too.

With that backdrop, let’s consider what “Dr. Gooch” from MHI said to the Scotsman Guide, as well as what occurred. There are no specific allegation being made. But the facts, quotes, narrative, and the outcomes after the shutdown will be considered. 

Let’s next look at some selected items from Scotsman Guide (SG) Media’s About Us page.

Scotsman Guide, the leading resource for mortgage originators, is published nationally every month in separate residential and commercial editions


Our History

Scotsman Guide Media is privately held company that has served the mortgage lending industry since 1985

Mission Statement

Scotsman Guide Media’s mission is to be the leading provider of information, resources and tools for professionals in the mortgage industry —in both the residential and commercial markets.

Toward this goal, Scotsman Guide Media has been taking the following steps

         Publishing educational articles and in-depth news-based features that keep mortgage professionals apprised of market trends and developments…”

The Daily Business News on MHProNews now turns to the actual SG article, starting with the date, time stamp, and featured image as shown.



Top Headlines 

Jan 22, 2019  16:50 ET.

Shutdown threatens manufactured-home industry

The government shutdown hasn’t widely affected the manufactured-housing industry yet, but a prolonged closure has the potential to stop deliveries of new manufactured homes all over the country, an industry trade group says. 

The U.S. Department of Housing and Urban Development’s (HUD’s) Office of Manufactured Housing, an agency that oversees the building code and certification process for manufactured homes, has been closed during what has become the longest government shutdown in U.S. history. This has only so far affected manufacturers producing homes that require letters of approval for alternative construction, according to the Manufactured Housing Institute (MHI), an industry trade group.  

HUD often opts to approve alterations in approved floor designs or other features in manufactured homes on a case-by-case basis.  Because of the shutdown, HUD’s office can’t do that, leaving some manufacturers in limbo, said Lesli Gooch, MHI’s senior vice president for government affairs.

“If you don’t have approval through the alternative-construction process, that house can’t be delivered because that house can’t receive the HUD code-certification label,” Gooch told Scotsman Guide News. “We have a lot of manufacturers.”

Gooch said one plant in Mississippi, for example, was awaiting approval last week from HUD to install an HVAC unit that isn’t on its approved list. That company is producing manufactured-home units for the Federal Emergency Management Agency (FEMA).

“Because HUD is closed, they are not going to get approval, which means the production of these FEMA units is on hold until they get approval,” Gooch said. She said the trade group is still investigating how many deliveries have similarly been disrupted.

“I don’t have a sense of how large a problem this is as far as production being halted because of the need to renew an alternative-construction letter or the need to obtain an alternative-construction letter,” Gooch said. “The Mississippi issue is one that I was contacted about just because it is one federal agency requesting homes, and they can’t be built because HUD is closed,” she said.

Gooch also said there is the potential for widespread problems should the shutdown drag on for another month. MHI believes there is a possibility that the supply of HUD tags could run out because of the closure and budget impasse.  

Every manufactured home that is built and delivered in the U.S. — roughly 8,000 per month — has to be inspected and certified as having met safety standards. Once inspected, the manufacturer is given a red-metal tag, which is affixed to the exterior of the building to verify that it meets the standard. The home can’t be delivered to a customer until it is tagged.

“Based on our research, the industry’s PIAs [primary inspection agencies] should have enough labels on hand to get through the end of February,” Gooch said. “If the government shutdown continues, early March is our first estimate of when a problem could develop.” 

For the duration of the shutdown, HUD has also stopped the Title 1 loan program, which backs a small number of chattel loans each year used by borrowers to buy manufactured homes that aren’t titled as real property.  

 ## End of SG article being reviewed ##

The original article from the Scotsman Guide is linked here, and a download of the screen capture of that article’s page as of the date of this Daily Business News on MHProNews post is linked here.

Now, let’s turn to two graphics from our evening market reports.  The first is from the evening of 1.23.2019.  This would be the day after Gooch’s quoted commentary, shown above.


Berkshire and MMI clearly have other interests, beyond manufactured homes, as is true of some of the other tracked stocks shown above. But Cavco is a factory-built housing focused firm. The majority of the tracked stocks fell on the day following Gooch’s comments.


The next graphic is from the evening of 1.25.2019, after the end of the partial federal shutdown was announced.


Virtually all tracked stocks moved up by the close of the market’s day following the partial federal shutdown. Next, look at what the broader markets did on 1.23.2019 and on 1.25.2019.


Note that there was already Washington, D.C. and media scuttlebutt that a deal to end the recent shutdown was already in motion at the time the Scotsman Guide article was published.  Note too what the broader markets did on both days, which largely closed up.



These 12 indicators are published every evening on the Daily Business News on MHProNews market summary and related featured report. Note that the markets generally rose both days, but on the 1.23.2019, the manufactured housing industry’s connected tracked stocks largely fell. It could be a coincidence. But what if Gooch’s article – intentionally or not – was used by traders and investors to reconsider some of their positions in manufactured home businesses?


Then consider this point.  There are arguably few manufactured home industry professionals, much less stock market watchers and investors, who would have even considered the notion that a partial federal shutdown could impact manufactured housing at all.

So why make did Gooch make those comments in the first place?

As was noted at the top of this column, Joe Stegmayer is under the cloud of an SEC subpoena. He stepped down as Chairman and CEO of Cavco, and the stock plunged as a result. A follow up report on that topic is pending, as there are new developments learned about that fiasco, which will be reviewed in the days ahead by MHProNews. 

But for now, we will simply note the obvious. Stegmayer is still MHI’s Chairman. He is an ex-division president of Clayton Homes, a Berkshire Hathaway company. Since the time that Triad Financial Services CEO Don Glisson, Jr was briefly their chairman, MHI apparently has had no problem with keeping someone on as chair that has come under a cloud of legal or media suspicion. Consider these three. 

   Better Business Bureau (BBB) “F rated” SSK Communities’ partner Nathan Smith

   Tim Williams, President and CEO or Berkshire Hathaway owned 21st Mortgage Corp, and

   Joe Stegmayer of Cavco Industries (CVCO) have all come under a cloud of legal, media, regulatory, and/or some other combination of suspicion. 

None of those 3 bothered to step down as MHI Chairman.   Although MHI has postured efforts for growth for years, the industry has steadily been consolidating. Sales have been moribund, in spite of overall quality and satisfaction that third party research has documented. One such example of their party praise is linked here.


Questions, Questions…

There ought to be some open questions from investigators that seek honest answers as to why Gooch would make these statements in the first place.

  • Who did or might have benefited from Gooch’s odd statements?
  • Who did this potentially impact – or which firms might have been harmed – by Gooch’s statements?
  • Were her arguably misguided comments merely foolish? Or where they a page out of the MHI play book – namely, actions and/or inactions that harm independents – that also fits loosely with a plot-line of the movie Wall Street?

What is certain is that Congressional hearings and an SEC investigation ought to be conducted related to several issues connected to the Manufactured Housing Institute. But it won’t be only about the article reviewed above. It should also be about the facts and evidence from articles linked below the bylines and the notices that follow.

We opened this with the words, “Timely information combined with money can move markets. Information may be legally or illegally used…”  There’s an affordable housing crisis.  Yet, manufactured housing is snoring instead of roaring.  MHI claims to be promoting the industry.  How did Gooch’s comments promote confidence?



See MHI President Richard ‘Dick’ Jennison’s comments, linked below the byline. Also see what MHI’s prior president said at this link here.


Corruption, waste, fraud, and other abuses in the Washington, D.C. metro are not new.  But that doesn’t mean that they should be tolerated.

Something has smelled in certain offices in Arlington, VA for some time. And it’s not a flowery aroma.  Rather, it’s arguably the stench of a string of troubling incidents and concerns connected to MHI that has made them worthy of suspicion, which our coverage and analysis of such #nettlesome things have made this pro-manufactured housing growth publication the most widely read trade media in this industry today. 

That’s MH “Industry News, Tips, and Views Pros Can Use” © where “We Provide, You Decide.” ## © (News, analysis, and commentary.)



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Related Reports:

You can click on the image/text boxes to learn more about that topic.


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

Bridging Gap$, Affordable Housing Solution Yields Higher Pay, More Wealth, But Corrupt, Rigged Billionaire’s Moat is Barrier

Midwest Manufactured Housing Federation Official Louisville Show Communique to MHProNews


“The Illusion of Motion Versus Real-World Challenges”

Production Decline Continues in November 2018









Kevin Clayton, Leslie Gooch Sound-off; Left & Right Agree? Manufactured Homeland, MHI, & You

August 14th, 2018 Comments off


KevinClaytonPhotoLesliGoochPhotoMHInsiderLogoMHProNewsLogoFactChecksDailyBusinessNewsMHProNews600x315To tee-up the Kevin Clayton, Lesli Gooch portions of this article, the Daily Business News on MHProNews will start with noteworthy development in media.  When voices from the political and economic left – and the conservative/libertarian economic and political right – broadly agree on a core issue, that alone should be headline news.


From Bill Moyers, or Democracy Now! among progressives, to Breitbart or the Thomas Sowell on the right, there are voices in the media – as well as news analysts – that for years have been raising concerns about the increasing concentration of media ownership.


Dan Rather quote from the compelling documentary video, Shadows of Liberty, posted on the linked page below.

Some are calling it an “oligopoly,” while others deem it them as “monopolies” of news and information. But the bottom line is that media has been dramatically consolidated in the last 2 decades.


What that means in practice is that the news you read, view or hear has someone’s agenda behind it.


Who says?

“Shadows of Liberty” Movie Introduction, Affordable Housing, and You

Take a look at some of the many possible sample quotes.


Deepa Kumar quote from the thought-provoking video documentary, Shadows of Liberty, posted on the linked page above.


#1) Why Should Manufactured Housing Professionals or Investors Care? 


A tiny fraction of a single percent of the U.S. population decides what’s news, and what is not.

When manufactured housing is widely misunderstood, one should consider the mantra of Marty Lavin, JD, and “follow the money.”

That ‘follow the money’ wisdom ought to be applied to those who select, cover, ignore and otherwise ‘frame’ the news; including the news that covers and impacts our necessary part of the safe, quality, affordable housing industry.


Danny Glover quote from the fascinating video documentary, Shadows of Liberty, posted on the linked page above.

Note that for years, the Daily Business News on MHProNews – most notably in our evening market report – has taken information from both sides of the left-right media divide. In other non-market reports, we periodically curate an topic or issue from a mainstream media source.  That’s fact checked or spotlighted because it is useful or insightful for the industry’s professionals, owners, investors, and others.

We’ve also stressed that publishing a quote has never meant that we agree with everything that source or person says.  More recently, we’ve phrased that at times, one must separate the ‘wheat and chaff.

Even some person or source that you may routinely disagree with, can have a terrific insight on an important issue.  The open mind, with probing questions, can benefit from the – who, what, when, where, why and how – approach.


Tim Williams 21st Mortgage Corp President and CEO Said It


Tim Williams, photo credit,

As Tim Williams, President and CEO of 21st Mortgage Corp – and the prior Chairman of the Manufactured Housing Institute (MHI) – keenly phrased it: “I know that Tony [Kovach, publisher of MHProNews] has corrected errors when they are brought to his attention. His publication accepts opinion articles or will share views in interviews that may differ from his own published position. My impression is that Tony isn’t looking for ‘an amen corner,’ rather, he wants a variety of views that get people to think, talk and take action.

The reason that comment of Williams is so timely is because

  • MHI’s SVP Lesli Gooch, Ph.D., and
  • Clayton Homes President and CEO, Kevin Clayton

both recently made oblique responses via MHInsider to concerns raised by voices here on MHProNews.

Clayton and MHI’s Gooch were likewise obliquely replying to voices from across the Potomac River from Gooch’s office in Arlington, VA.

What they did was what one industry observer called “razzle dazzle.”

  • They didn’t directly respond,
  • they didn’t refute a single concern.
  • Rather, it was arguably cheer leading.  Spin. Misdirection.  ‘The future is this way! – with nary a thought as to what the recent past tells us about those who are speaking, and what their past behaviors have allegedly wrought.

Graphic by MHProNews, using information provided by each corporation, or named entities.

 The linked article below reveals how the above outcome occurred since
Warren Buffett’s manufactured housing buy-in began.

FEDs, MHI, Buffett’s Berkshire’s Clayton Homes Moat, Affordable Housing, and Billion$ in Manufactured Home Market Manipulation


Weaponizing or Surprising the News?

Agree, disagree – or fold your arms without any position or comment – but don’t suppress free speech.

When government surprises free speech, there are constitutional remedies.

But the issue of free speech, controlling what is or isn’t published, and suppressing speech, become trickier when it comes to when a corporation silences, spins, or unjustly parses information.


Most manufactured home industry professionals don’t realize the scope of the Berkshire Hathaway (BH) Media Group’s direct assets. Beyond these, there are other media ties and interests that they arguably can leverage. Why haven’t they? How does this reality compare with the claims of Kevin Clayton and MH Insider?

This is why those who publish, speak, or act in public have to be held to account.

Fact checks are useful in that regard.  A frank discussion on transparency, in the spirit of the late ELS Vice Chairman, Howard Walker’s words (linked below) would be welcomed by many in the industry, including within MHI’s membership.


Thoughtful words, worth pondering. See the story, linked here.

It would be useful if Kevin, Tim, Lesli, or Dick would agree to discuss or debate publicly their various actions and inactions. Let that discussion be done on video, so all can see it.  There are several upcoming events where that could be done, or it could be handled virtually, with no travel needed.

  • Wouldn’t an open conversation be a step toward increased MHI and Clayton transparency?
  • If there is nothing to hide, then why are they ducking the conversation and relevant topics?
  • Why oblique replies, that duck serious issues, instead of direct replies to fact and evidence-based questions and concerns?


MHI’s Gooch ‘Responds…’


Control of the Media

In serious MHVille trade publishing, essentially, all but MHProNews have arguably been co-opted to various degrees by the “big boys,” logically in pursuit of controlling the narrative, in pursuit of their own agenda.

That agenda has for some years, included more consolidation, per industry sources, including those in MHI, or formerly with them.


MHProNews looks at the facts, considers the sources, and follows the evidence. Earlier last year, and for years before, MHI routinely replied promptly to all our 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 or offer a cogent explanation?

We’ve asked before, why didn’t Berkshire Hathaway use their own newspapers for years to reply to flawed reporting about the manufactured home industry?  After we raised that questions a several times, magically, the Omaha World-Herald newspaper that Berkshire owns published an article on manufactured housing.  While it wasn’t perfect, it was a start.  What’s next? Will more industry pressure make them do it more often?  If not, what excuse will they give?

Weaponized, Faked News Harms Manufactured Housing Homeowners, Professionals

Where is the support for the National Association of Realtors ® report by Scholastica ‘Gay’ Cororaton that was overall so positive for manufactured housing?

As of yesterday afternoon, no obvious support online was discernable by a Google search for Clayton, Berkshire, or MHI and the NAR’s positive report about manufactured housing.  Why haven’t they beat the drums publicly on that NAR “Making the Case for Manufactured Homes,” or the more recent report linked here?

Going forward, if Kevin is serious about getting help from “Warren” on the image/education issue, from now on, instead of the low-brow-outcomes from email or other limited visibility shares – why not give professional BH Media Group and their other media communications assets the nod to carry such good news as Cororaton’s report?

Wasn’t what Kevin and Lesli Gooch said in print arguably indirect reply to issues we’ve raised?

There is no reason why MHI, and/or Clayton and other Berkshire brands couldn’t use their media holdings or connections to clear up each and every misconception about manufactured housing. Buffett did respond to direct slams on Clayton by the Seattle Times.  If what Kevin Clayton says is sincere, then why have the BH Media Group not done the same for every misrepresentation about manufactured housing?


The Jim Ayotte Insight


Jim Ayotte, Florida Manufactured Housing Association (FMHA) made the following insight.

No one can respond to something that they are unaware of, but once something becomes clear, then prudent steps can be taken.



There is no denying the trend lines, documents, and quotes-in-context related to consolidation of the industry, as shown in the linked and related reports herein, and further below.


Kevin Clayton Said…


The statement about shipment percentages is either mistaken or demonstrably misleading. See the shipment trends, and percentages in the graphic below. 


There are a growing number of industry voices that believe that BH/CMH and MHI have by various action/inaction has kept manufactured home sales at historically low levels. Evidence? See Related Reports and videos, linked below, which quotes and cites BH, MHI, CMH, 21st Mortgage Corp, and other sources.

Neither Clayton, nor Berkshire’s Omaha World-Herald, nor Clayton has explained the following.

Why didn’t MHI’s Lesli Gooch ask HUD for Pam Danner’s replacement? See the Washington Post, or the report linked below.

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

Is MHI still supporting Vic DeRose at HUD for the Office of Manufactured Housing Program administrator position?  Who replaces Pam Danner is obviously important. MHI could easily strive to work for someone good, or someone equally problematic in place.  Why would they allow that to latter to happen?  Why did they allow Pam Danner to remain so long, when they admitted to the Washington Post to making no direct pushback? The reason given by some industry veterans for MHI’s foot-dragging is that heavy regulations harms smaller companies more than bigger ones. Rephrased, it is an oblique way of building the Berkshire Moat.  See those Buffett and Kevin Clayton interview videos, linked here.


What about the DOE Energy Rule U-Turn? Why was MHI on the wrong side of that topic, and then after months of outside pressure, have do a 180?

What about concerns over manipulations of the DTS process by the GSEs?  What about the conflict of interest for Fannie Mae being a member of MHI?

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

Why did MHI fail to properly promote other lending options, besides those that seemed to be the most profitable for Berkshire brands? See the report, linked above, and the details that flow from that post.

Since MHI is praising S 2155’s MLO rule change, why didn’t they do that same deal 3 years ago, during the Obama Administration, when the CFPB reportedly made that option possible via consumer groups and non-profits, had MHI agreed to dropped the points-and-fees?  After 3 years, they did just that – drop the chase for more points and fees.


Wrong, or Misleading, Time and Again?

How can they be so often wrong?  Or misleading?

Isn’t their effort to control the media narrative within the industry part of that pattern? And isn’t their failure to defend and promote the industry, part of the problem?

If MHI or Clayton are the solution, then why have so many retailers and independent producers gone out of business, or were economically pushed into a sale to one of the big boys?

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

That’s not to say that everything that MHI does is wrong.  Ditto that for Clayton/Berkshire.  But given the history of often false or misleading statements, why should anything new be expected?  Kevin is saying now that they will promote, but in the video linked here, Clayton said they were ready about 7 years ago to do an image/education campaign.  Why did they wait?  Was it to consolidate more?

‘They did it before, is there any reason why they won’t do it again?’

They Did It Before…Sunday Morning Manufactured Home Industry News Headline Recap July Aug 5, 2018

As an independent publication, service provider and consultant that MHI long praised, their behavior-changes starting in 2014 forced us as a business enterprise to look more closely.  Why did they arguably try to undermine our pro-Industry operation – while we were a dues paying, supportive members?

If they did it to us, what’s to keep them from doing it to you and your operation too?  As or more important, haven’t they done it to thousands of businesses already?


If the evidence suggests – and neither Clayton nor MHI will deny or defend to the contrary – that they manipulated the market to the detriment of the industry, why should industry professionals trust or believe them now?

If they did it before, what’s to keep them from doing it again?  And if we and so many others who have raised such concerns were wrong, why aren’t they using their vast media resources to routinely correct the record on manufactured homes?


The Bottom Line?

Not only is capital and access to lending power, but so is information.  There are several voices outside of manufactured housing that believe they are behaving in a monopolistic fashion.

Seattle Times -Federal Investigations-Berkshire Hathaway’s Clayton Homes, GuruFocus Spotlights Buffett’s Clayton’s “Unethical,” Monopolistic Moat

What about you?

Progressive “Nation” Reports on Monopolies Cites Buffett, Clayton, Others – MH Industry Impact?

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Rand Ghayad’s HuffPo OpEd questions Dodd-Frank factor in Lower U.S. Employment

August 26th, 2014 Comments off

rand-ghayad-phd-the-brattle-group=credit-posted-daily-business-news-mhpronews-com-Rand Ghayad, PhD, questions which is adding to the depressed U.S. labor market more, regulations or a lack of demand for goods and services? Writing in the Huffington Post, Dr. Ghayad cites Bureau of Labor Statistics (BLS) figures pointing to only 0.3 loss due to “government regulations/intervention,” vs. “25 percent were laid off because of a drop in business demand.”

A deeper dive by MHProNews into Ghayad’s statements reveals this quote:

The bottom line is an old story: regulation has raised costs and made business opportunities to sell goods and services insufficiently profitable. The new twist is that these fears are suppressing current investments and hiring, and are thus a major cause of our long-term unemployment problem.”

Ghayad also acknowledges that too big to fail, something Dodd-Frank was supposed to help ‘fix,’ has actually resulted in larger financial institutions, not smaller ones. “The U.S. largest banks have grown only bigger since the financial crisis — by as much as a third.”

Ghayad’s survey fails to ask about the impact of other regulatory burdens on business and the economy, such as the Affordable Care Act (ACA a.k.a. ObamaCare). “Blaming” lower employment on Dodd-Frank alone would be an overstatement. But as veteran manufactured housing professionals know, Dodd-Frank is suppressing some loans which where previously being made, which in turn reduces sales and thus the ability for would be financing sources to fill demand. To learn more, see the Industry in Focus report on HR 1779. ##

(Rand Ghayad, PhD photo credit: The Brattle Group)