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

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

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

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

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

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

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Credit: Scott Lewis, Creative Commons.

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

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

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M. Mark Weiss. Credit: MHProNews.

DTS does not stand for ‘Duty to Study.’

Weiss also commented on Director Watt’s actions.

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

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

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

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

(Image credits are as shown above.)

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RC Williams, for Daily Business News, MHProNews.

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

MHARR to FHFA: Duty to Serve Without Chattel is Unacceptable

January 31st, 2017 Comments off
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Capitol Building credit, Wikipedia. MHARR, Mark Weiss images MHProNews. MHARR logo is their intellectual property, and is shown here under fair use guidelines.

Washington, D.C. – The Manufactured Housing Association for Regulatory Reform (MHARR) reports to MHProNews that, at a Duty to Serve (DTS) “listening session” conducted by the Federal Housing Finance Agency (FHFA) in Chicago, Illinois on January 25th,  it advised FHFA officials and representatives of the FHFA regulated Government Sponsored Enterprises (GSEs), that the December 29, 2016 FHFA final DTS rule which does not mandate manufactured housing chattel loan securitization and secondary market support by the GSEs is unacceptable as currently written.

In comments and a detailed written statement at the meeting, MHARR stressed that any DTS rule which fails to provide meaningful and timely securitization and secondary market support for chattel loans, which comprise upwards of 80 percent of the manufactured housing consumer finance market, cannot conceivably satisfy the mandate imposed by Congress via the DTS provision of the Housing and Economic Recovery Act of 2008 (HERA).

MHARR says that while the FHFA final rule and related guidance proposal issued on January 13th have been lauded by some as bringing consumers and the industry “closer to the realization of a manufactured housing chattel loan securitization and secondary market support program that would end decades of discrimination against the largest segment of the manufactured housing finance market,” the reality is that the final rule contains no affirmative requirement for GSE support of manufactured home chattel loans and no meaningful penalty or sanction for their continuing failure to serve that part, or any other part, of the manufactured housing finance market.

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Credit: Neon Tommy.

The final rule and evaluation guidance would only require that the GSEs consider such support, a formulation that particularly given the GSEs history, would allow them to either bypass and reject such support or engage in endless and ultimately meaningless research and outreach, with nothing more than a perfunctory explanation.

MHARR contends that the FHFA rule as confirmed at the meeting would leave major FHFA regulatory hurdles including its rule requiring approval of new products that could prevent or significantly delay any actual GSE support activity for manufactured housing chattel loans, in place.

The rule would thus continue to exclude the vast majority of potential manufactured housing purchasers from the market, because they cannot afford to pay higher-cost manufactured home chattel loan interest rates that are needlessly inflated by the discriminatory lack of GSE securitization and secondary-market support for such loans and by the lack of full and robust free-market competition, which is artificially suppressed by those same policies.

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Danny Ghorbani, photo credit, the Journal.

While discussing the GSEs, former MHARR President Danny Ghorbani further confirmed concerns.

Despite forty-years of on-again, off-again flirtation with the industry and its consumers, are socially active and engaged, but fiscally removed and divorced from each,” said Ghorbani.

[The GSEs] talk the right talk and go through the right motions, attending and sponsoring industry events and even hiring industry members as consultants to advise them, but have never formulated and implemented a positive and workable program to securitize the chattel loans that would allow low, lower and moderate-income consumers to become homeowners an underserved market that Congress decreed nine years ago, the GSEs must now serve.

For the full statement from MHARR, click here.

The Daily Business News covered the FHFA in a report linked here

Masthead commentary on this issue is linked here. ##

(Image credits are as shown above.)

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RC Williams, for Daily Business News, MHProNews.

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