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No Seat at the Housing Policy Table

February 4th, 2010 No comments

Senior HUD officials, at a December 2, 2009 hearing of the House Financial Services Committee, were asked why the non-career Administrator position for the HUD manufactured housing program — authorized by Congress as part of the Manufactured Housing Improvement Act of 2000 — is vacant and has been vacant for most of the past ten years. When they answered that such “Schedule C” appointees were more urgently needed elsewhere and that manufactured housing did not merit a Schedule C appointee, a Committee member asked whether Congress had been “wrong” or “stupid” to provide for a non-career program Administrator. While HUD had no response, the industry itself had better have a firm grip on why Congress wanted a non-career official to head the HUD program if it is to have any hope of securing such an appointment and the significant benefits that Congress intended to result.

For ten years, the tendency has been to focus on the non-career Administrator as a regulatory position. Thus, Congress — in response to program deficiencies that had been exposed over a nearly 25-year period — authorized a non-career Administrator to ensure a transparent and accountable manufactured housing regulatory program that is responsive to its stakeholders, senior HUD management and the public at large. And while this view is accurate – as far as it goes — it is much too narrow and misses many of the key reasons why Congress concluded that the HUD program must have an appointed non-career Administrator.

In addition to being a regulatory position, the non-career Administrator is, even more importantly, a policy position with critical policy functions that parallel the main goals of the 2000 law — (1) ensuring the fundamental reform of the HUD program; and (2) ensuring the full recognition and treatment of manufactured homes as housing, rather than “trailers,” both within and beyond HUD.

First, Congress correctly anticipated that key reforms of the 2000 law would be resisted by career regulators at HUD. It thus provided for a non-career appointee to head the program and act as a guardian for every other program reform included in the law, in order to ensure their full, proper and timely implementation. Consequently, it is no surprise that, in the absence of a non-career Administrator, the implementation of multiple reform aspects of the 2000 law has been — and continues to be — obstructed, minimized, ignored, undermined, altered, delayed or rolled back. Indeed, the track record of the last ten years shows — as Congress is now beginning to understand — that without a non-career Administrator, the fundamental character and culture of the HUD program will not change and the program reform and modernization envisioned by Congress will simply not occur.

Second, and even worse, the absence of a non-career Administrator leaves the industry and its consumers without a seat at the policy-making table in Washington, D.C. The 2000 reform law established the non-career program Administrator to act as the lead advocate for “the acceptance of the quality, durability, safety and affordability of manufactured housing” under section 620 of that law. This advocacy role extends well beyond the HUD regulatory program — to issues including parity in financing, placement, utilization and acceptance, among others – and was designed to ensure, at a minimum, that manufactured housing and consumers of manufactured homes would have a full and equal place in all policy decisions at HUD and in all HUD housing programs, during every Administration.

Without a non-career Administrator to interface with each presidential administration at a policy level, however, both manufactured housing and the HUD manufactured housing program have effectively been segregated from the senior political leadership and decision-makers at HUD, and frozen out of the mainstream of that agency. As a result, manufactured housing has remained under the control of career regulators and an entrenched enforcement contractor who are not interested in change and are more concerned with the nuts and bolts of regulation rather than effective policies that promote the availability, utilization and financing of affordable manufactured housing. Manufactured housing, therefore, does not show-up, either literally or figuratively, on HUD’s policy radar screen and remains today — as shown at the December 2, 2009 congressional hearing — a second-class “step-child” at HUD.

A small but telling example of this disconnect is HUD’s internet website. The initial page has direct links to a multitude of housing programs, but no reference whatsoever to manufactured housing, no indication that either HUD or the Federal Housing Administration (FHA) even have programs for manufactured housing, and no direct link to either program. Thus, the nation’s leading source of affordable, nonsubsidized housing is not even acknowledged by the primary public information resource of the federal government’s housing agency. And while this might seem minor, in itself, it is a symptom of the broader exclusion of manufactured housing from the mainstream at HUD and illustrates why the HUD manufactured housing program and the HUD Code manufactured housing industry are both in a state of severe decline.

Some may contend that a non-career appointee is heading the program, because HUD’s manufactured housing office falls under the jurisdiction of the Assistant Secretary for Housing. And while, again, this is true as far as it goes, the reality — as confirmed by repeated experience over the course of 35 years – is that these officials, with extremely broad responsibilities, cannot, do not, and do not want to get involved with the unique complexities and intricacies of the manufactured housing program, on a policy or any other level. As a result, the Assistant Secretaries, historically, have simply gone along with the decisions and recommendations of career program regulators and program attorneys within the Office of General Counsel. This is a far cry from the independent, non-career appointee envisioned by Congress, who would be immersed in manufactured housing 24-7, have direct contact with each Administration, and the latitude, freedom and will to alter the status quo as necessary — instead of being part of that status quo.

Similarly, many within the industry a about the importance of a non-career Administrator for the HUD program and the need to fill that position as quickly as possible. Unfortunately, though, except for MHARR – representing the industry’s smaller businesses that are the most directly and negatively impacted by the program’s decline – no one has done any heavy lifting on this issue and others, in fact, are helping to preserve the status quo. And while MHARR will continue to leave no stone unturned in its effort to have a non-career Administrator appointed, others who thus far have paid only lip service to this matter need to recognize the far-reaching negative implications of not having a non-career appointee in charge of this important housing program.

In MHARR’s view, every possible effort must be made to secure a non-career Administrator for the HUD manufactured housing program and bring the HUD Code industry to the policy table in Washington, D.C.

Read MHARR’s latest news release on this subject »

MHARR is a Washington DC-based national trade association representing the views and interests ofproducers of federally-regulated manufactured housing.

Modular builder propose Haiti homes solution

February 3rd, 2010 1 comment

American modular, pre-fab and manufactured home producers interested in exporting homes to another country – in this case Haiti – face many problems to export houses to another country. The most important matter is transportation and shipping of 400,000 units. One option to consider is to establish a large American Housing style Manufacturing plants to build the same house there in Haiti, to help their local economy. One drawback is time to build the facility.

The Alternative Option:
American modular, prefab and manufactured home producers could build suitable homes for Haitians almost immediately. As the inventor of a Modular Housing System, I know a firm such as ours could build 1000 prefabricated component homes a month or more based on the plan and facility with installation manual ready for assembly on the site with one certified builder, simple tools and local unskilled worker.

Our firm would certainly like to be considered for this type of project and I’d be pleased to personally help with alternative and sustainable modular aluminum framing solution utilizing other industries prefabricated panelized products like SIP or stud wall, roof (wood or steel) for quick construction of affordable housing for Haiti.

Finally, there could be a blend of the two options: we could use American producers like ourselves to build homes for Haitians immediately, and we could also begin the task of building a facility in Haiti for local construction efforts. I’d be willing to help with establishing a facility in Haiti as would other factory built home producers.

The key is to get a firm plan and begin to act.

Tim Siahatgar
MHS Building System

White House reply to MHMSM.com initiated discussion

January 28th, 2010 5 comments

In a reply to correspondence with President Barack Obama by our www.MHMSM.com editor, here is the message that came in from the White House…


Dear Friend:

Thank you for writing. The images from Haiti of
collapsed hospitals, crumbled homes, and men and women
carrying their injured neighbors through the streets are truly
heart-wrenching. As we learn more about the extent of the
devastation, our thoughts and prayers are with the people of
Haiti.

I have directed my Administration to respond with a
swift, coordinated, and aggressive effort to save lives. The
people of Haiti will have the full support of the United
States Government in the recovery and rebuilding effort,
including the humanitarian relief–the food, water, and
medicine–that Haitians will need in the coming days.

This is also a time when we are reminded of the
common humanity we all share, and Americans have
always responded to these situations with generosity of
spirit. If you would like to support the urgent humanitarian
effort in Haiti, I encourage you to visit our website where
you can learn more about how to contribute:

http://www.WhiteHouse.gov/HaitiEarthquake

Americans trying to locate family members in Haiti
are encouraged to contact the State Department at (888)
407-4747.

We will continue to stand with the people of Haiti
and keep them in our thoughts and prayers.

Sincerely,

Barack Obama


This response came in prior to the President’s State of the Union Address, where he often spoke about jobs. His reply does not specifically address the pressing issue of using America’s factory-built housing industry as part of a concerted response that would house Haitians and create American jobs building strong, modest homes and installing those homes under American leadership. The http://www.mhmarketingsalesmanagement.com/blogs/tonykovach/a-call-to-action/ still makes sense, and we as Industry members should continue to press for a specific response from the President and from your Senators and Congressman.##

MHARR Washington Update 1/27/10

January 28th, 2010 No comments

Posted by Danny Ghorbani – MHARR

Sprinkler Mish-Mash Designed to Mislead Industry
HUD Takes Shot at Industry, Consumers and Defies Congress
Unexplained Delays Continue on Financing – Suspicion Grows

Sprinkler Mish-Mash Designed to Mislead Industry

Grassroots industry concern over the erosion of federal preemption is wellfounded, as a combination of HUD regulators, industry enablers and research consultants continue to press yet another backroom “deal” — this time on fire sprinklers. This is another example of the type of ill-advised industry “compromise” on key issues – while most grassroots industry members are kept in the dark or provided misleading information – that has devastated the industry in Washington, D.C.

Read more…

Tackling and Blocking: the Issues that Face Manufactured Housing Today

January 28th, 2010 No comments

Posted by:
Richard J. “Dick” Klarchek
President, Capital First Realty
(MH Retailer and Manufactured Housing LLCs)

Working with the government has become an integral part of most businesses today, and since the construction side of the manufactured housing industry is HUD regulated, our industry is perhaps more impacted than many by government. While it is critical to seek to work effectively and positively, it is equally important to balance the desire to ‘get along’ with the need to advocate and advance the causes critical to the success of manufactured housing in the future.

Read more…

HUD’s Exposed Plan for the Manufactured Housing Industry is Unacceptable

January 25th, 2010 4 comments

Posted by Danny Ghorbani, MHARR

As has previously been reported, a steadily expanding number of members of Congress have been making inquiries to senior officials at HUD regarding the declining state of the HUD Code manufactured housing industry, the continuing inability of consumers to access public and private financing to acquire affordable, non-subsidized manufactured homes, as well as the Department’s management of — and plans for — the unique HUD (Title VI) manufactured housing program and FHA manufactured home financing. Throughout 2009, these congressional inquiries became more urgent, more specific and more pointed, as industry production and sales fell below 50,000 homes (its lowest output since 1950), and members of Congress became more concerned about closures of manufactured housing businesses (particularly smaller concerns) and related job losses, as well as the unavailability of manufactured home consumer financing in their districts and states.

Although HUD officials responded to these inquiries anecdotally and in a fragmented manner at various meetings and as part of congressional hearings, an extraordinarily articulate and well-focused December 2, 2009 inquiry from Rep. Travis W. Childers (D-MS), has now elicited a January 11, 2010 written response from HUD that provides a bleak and shocking window into HUD’s views concerning — and plans for — the federal manufactured housing program, consumers financing, the HUD Code industry and consumers of manufactured housing that have not previously been exposed in such frank detail. The revelations in this response — both stated and implied — are remarkable and should spur all program stakeholders to take stock now and address their implications for an industry and consumers already facing unprecedented challenges and obstacles.

Enclosed with this communication are copies of Congressman Childers’ December 2, 2009 inquiry letter and HUD’s January 11, 2010 response, together with a complete paragraph-by-paragraph analysis of HUD’s response. This packet is a must-read for all those with an interest in manufactured housing, including industry members, consumers and elected officials.

Based on the information exposed by these documents, the following priorities need to be pursued and implemented:

Regarding the HUD manufactured housing program and public financing —

  • The appointment of a non-career Administrator for the HUD manufactured housing program as provided by Congress in the Manufactured Housing Improvement Act of 2000 (2000 reform law). Based on the track record compiled while this position has been vacant for the past five years, without such an appointed Administrator, nothing else about the program will change.
  • Issuance of final rules implementing improvements to the FHA manufactured housing program approved by Congress in the Housing and Economic Recovery Act of 2008 (HERA) and the removal of the existing Ginnie Mae moratorium on the securitization of FHA Title I loans.
  • Full and proper implementation of all manufactured housing program reforms contained in the 2000 reform law.

And regarding private consumer financing, on a parallel track, with the Federal Housing Finance Agency (FHFA) —

  • Full and expeditious implementation of the HERA-based “duty to serve underserved markets” mandate for the two Government Sponsored Enterprises (GSEs).

Each of these priorities is critical to the recovery of the manufactured housing industry and to the availability of affordable non-subsidized housing to millions of Americans and particularly lower and moderate-income families. Accordingly, their implementation should be vigorously pursued by all stakeholders in the HUD manufactured housing program, by Congress and by the Administration.

Click to download Analysis of HUD’s Response to Congress

Welcome to Industry Voices

January 18th, 2010 No comments

This guest blog is provided so that Industry Voices can sound off on topics of interest or concern to the factory built housing business.  You can provide a brief, moderate or long column  – which should be emailed to the www.MHMSM.com editor Tony Kovach at latonyk@gmail.com –   with the words Industry Voices Blog in the subject line for editing checks and placement.  We will promote Industry Voices blog comments and columns, so thousands can hear these perspectives.

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