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Manufactured Housing Institute Responds to Doug Ryan-CFED commentary on CFPB report on Manufactured Housing Finance

October 6th, 2014 No comments

Tony,
As the national association serving as the voice of the manufactured housing industry, Tim (Williams) asked that MHI respond to your inquiry. Our official response is provided below.

Doug Ryan and CFED have been consistent supporters of manufactured housing and continue to recognize manufactured housing as an important source of affordable housing for low- and moderate income families, particularly in rural and underserved communities.

Unfortunately, they fail to recognize the valuable role retailers and sales representatives have historically played in helping consumers identify financing alternatives. Ryan's message insinuates the industry is somehow preventing consumers from selecting less expensive real estate-secured mortgage loans. He says, "many borrowers of chattel products could have qualified for traditional, less expensive mortgages but did not get the chance simply because they were not offered or made aware of the options.”

mhi-logoAs the regulations are currently written—this is what MHI is attempting to fix in HR 1779/S 1828—the retailer cannot help the customer find a mortgage lender or inform the consumer of alternatives. The consumer needs the retailer’s help to become informed of the financing alternatives.

Today, a consumer might contact a dozen conventional mortgage lenders without locating a lender willing to assist them with a low balance mortgage. Prior to the CFPB Loan Originator compensation rule (CFPB defines sales commission from the sale of a home as meeting the compensation definition under the Loan Originator rule), a retailer representative could discuss financing alternatives with consumers including conventional mortgage lenders who offer low balance conventional mortgage loans.

Since the Loan Originator rules became effective, it has become nearly impossible for a retailer to assist consumers without inadvertently becoming considered a Loan Originator and becoming a covered person under Bureau regulations. CFED wants consumers to be informed of financing alternatives, but the people who have the best opportunity to inform them are effectively barred from having those conversations.

Ryan adds, “Indeed, one clear way to address this issue would be for industry to support titling reform that would give families the option to title their homes as real estate and the opportunity to access real estate loans."The manufactured housing industrysupports legislation in all states to provide the alternative of titling manufactured homes as real estate where the home is sited upon land owned by the consumer and when financing is needed, the consumer pledges a first lien position in the land.

jason-boehlert-manufactured-housing-institute-(c)mhpronews-com-75x75-.gifJason Boehlert
Manufactured Housing Institute (MHI)
Senior Vice President of Government Affairs
1655 North Fort Meyer Drive
Suite 104
Arlington, VA 22209

Related Links:

1) – MHI's Response to CFPB's Report (Editor's Note, the MHI link includes the full CFPB report as a free download)

2) – MHARR's Response to RV legislation and CFPB's Report on Manufactured Housing

3) – CFED's Doug Ryan sounds off on Consumer Financial Protection Bureau (CFPB) Report on Manufactured Housing and MH Financing

4) – CFPB Report on Manufactured Housing Signals Areas of Future Concern

    (Editor's Note: The views expressed by Jason Boehlert are his own and/or those of the MHI, and should not be construed to be the views of MHProNews or our sponsors.Other viewpoints on this or other industry topics are encouraged.

    MHProNews plans anIndustry in Focus Reportusing extensive comments from a range of industry professionals on this topic. Watch for it mid-week at the news/reports module link above.)

    CFPB Report on Manufactured Housing Signals Areas of Future Concern

    October 6th, 2014 No comments

    On Tuesday, the Consumer Financial Protection Bureau (“CFPB”) released a white paper summarizing their research on the manufactured housing industry. The Bureau relied upon information compiled by various surveys, data available pursuant to the Home Mortgage Disclosure Act (“HMDA”), and voluntary submissions of information by institutions in the manufactured housing industry. Although the CFPB acknowledges that they are still seeking additional information on the industry, the report, among other things, provides a detailed description of the manufactured housing market, the demographics of consumers who reside in manufactured homes, and the impact of the current regulatory climate on the industry.

    The CFPB also developed seven “key findings” from this research, many of which likely will come as no surprise to those actively involved in the manufactured housing industry. For example, the Bureau explains that manufactured homes are more likely to be located in non-metropolitan areas than site-built homes, and that manufactured homes typically cost less than site-built homes. These types of findings lead the Bureau to conclude that the industry is “an important source of affordable housing, in particular for rural and low-income consumers.” On the other hand, however, they believe that “these same groups include consumers that may be considered more financially vulnerable and, thus, may particularly stand to benefit from strong consumer protections.”

    With respect to the specific protections that may be necessary, the CFPB declines to make any conclusions and, in fact, leaves certain questions open for further research. For example, the white paper describes how consumers in the manufactured housing industry can either utilize real-property financing or chattel financing, and explains some of the short-term and long-term trade-offs that exist between the two options. However, it appears that the Bureau is concerned with, and wants more information on, “[t]he extent to which consumers are aware of these trade-offs and how consumers weigh them.” This information indicates that the CFPB will pay particular attention to whether or not borrowers are adequately informed about the trade-offs associated with pursuing chattel financing instead of real-property financing.

    The report does acknowledge that some of the title XIV Dodd-Frank Act amendments, including those made to the Home Ownership and Equity Protection Act (“HOEPA”) and the Truth in Lending Act (“TILA”), expand protections for consumers in the manufactured housing market. They also briefly describe the actual and theoretical impacts of these laws and the underlying regulations. For example, they admit the possibility that additional disclosure requirements and other burdens could increase the cost of extending credit to consumers seeking financing for a manufactured home. Prior to the rules being finalized, the CFPB received comments expressing concern that the proposed HOEPA high-cost thresholds would disproportionately impact small-balance loans that are often used to purchase manufactured housing. Many in the industry believe that these standards, which have been in effect since January 2014, are in fact reducing the availability of credit in the manufactured housing market because these loans are now classified as high-cost.

    Similarly, the new Loan Originator Compensation (“LO Comp”) rules in TILA may also be increasing the consumer’s cost of obtaining credit for a manufactured home. Unlike realtors, manufactured housing retailers are not exempt from the LO Comp rules. In order to avoid being considered a loan originator, and to avoid having to go through an expensive licensing process, manufactured housing retailers are often not referring potential borrowers to specific creditors that they know are willing to extend financing for a manufactured home. This has resulted in consumers being left unaware of which creditors are willing to extend credit and the requirements each creditor has for approving a loan. Consumers, therefore, are submitting more applications and, because of the lack of important information, are more frequently being needlessly denied.

    Despite acknowledging that the manufactured housing industry still has concerns about the impact of the CFPB’s new rules, the Bureau declines to accept that the rules have adversely impacted the market. Instead, they “will continue to monitor the effect of [their] rules on the manufactured housing industry and on consumers who purchase or seek to purchase manufactured homes.” In the meantime, the Preserving Access to Manufactured Housing Act, which would address at least some of these concerns, remains in Congress.

    If nothing else, this white paper should serve as a warning that the CFPB has taken an interest in the manufactured housing industry. The Bureau is continuing to monitor the impacts of the new mortgage rules on the manufactured housing market, which could signal that the Bureau may be open to making adjustments to the rules that would reduce burdens on creditors and lower the cost of credit for consumers. However, they have also tipped their hand to at least one area of ongoing concern. Creditors originating chattel mortgages should pay particular attention to the amount, and types, of information that is being provided to borrowers and should ensure that they are fully informed of their financing options and the costs and benefits associated with each.

    ##

    Republished with permission. This article first appeared in Financial Services Litigation & Regulatory Compliance Alert, a publication of Bradley Arant Boult Cummings LLP.

    About the Authors:

    Jonathan_R_Kolodziej-jd-bradley-arant-boult-cummings-llp-posted-industry-in-focus-mhpronews-com-75x75-Jonathan R. Kolodziej, JD, is an associate in the Birmingham office where he is a member of the firm’s Financial Services Litigation and Compliance Team. His regulatory compliance practice involves assisting some of the nation’s largest financial institutions and mortgage companies as they implement, and demonstrate compliance with, various obligations imposed on them by the Consumer Financial Protection Bureau (CFPB) and state banking regulators.

    bill-matchneer-jd-formerly-hud-cfpb-now=bradley-arant-boult-cummings-llp-posted-industry-in-focus-mhpronews-com-75x75-

    William “Bill” W. Matchneer, JD, recently joined the Washington DC office as senior counsel. He retired from the CFPB in February, where he had been one of the team leads for the regulations implementing the Dodd-Frank mortgage requirements. He previously spent ten years at HUD as manager of the Office of Regulatory Affairs and Manufactured Housing and Senior Counsel for Regulatory Enforcement.

     

    Related Links:

    1) – MHI's Response to CFPB's Report  (Editor's Note, the MHI link includes the full CFPB report as a free download)

    2) – MHARR's Response to RV legislation and CFPB's Report on Manufactured Housing

    3) – CFED's Doug Ryan sounds off on Consumer Financial Protection Bureau (CFPB) Report on Manufactured Housing and MH Financing

    4) – Manufactured Housing Institute Responds to Doug Ryan-CFED commentary on CFPB report on Manufactured Housing Finance

    (Editor's Note:  The views expressed by Messrs. Kolodziej and Matchneer are their own and/or those of the organization they work for, and should not be construed to be the views of MHProNews or our sponsors. Other viewpoints on this or other industry topics are encouraged.

    MHProNews plans an Industry in Focus Report using extensive comments from a range of industry professionals on this topic. Watch for it mid-week at the news/reports module link above.)

    CFED’s Doug Ryan Sounds off on Consumer Financial Protection Bureau (CFPB) Report on Manufactured Housing and MH Financing

    October 4th, 2014 No comments

    cfed-logo-posted-industry-voices-guest-blog-mhpronews-com-.gifThe CFPB report supports what CFED and other nonprofit organizations have said in recent years:  Manufactured Home loan borrowers are vulnerable to expensive products and are often not well-served by the current financing market due to the lack of competition, lack of liquidity and the costs of the loans.

    I have no doubt, as the Bureau reported, that many borrowers of chattel products could have qualified for traditional, less expensive mortgages but did not get the chance simply because they were not offered or made aware of the options. Indeed, one clear way to address this issue would be for industry to support titling reform that would give families the option to title their homes as real estate and the opportunity to access real estate loans.

    The report supports, quite explicitly, the need for the Bureau’s current rules to remain in place and enforced. As the Bureau wrote, “the manufactured housing borrowers being charged interest rates or upfront fees above the HOEPA thresholds are the very populations that HOEPA is designed to protect."

    I also believe that this report, and related efforts by industry and CFED and its nonprofit partners, offers an opportunity to develop new loan products, expand the pool of lenders and, ultimately, lower the costs of borrowing.

    CFED absolutely believes manufactured housing must be part of the affordable housing solution in communities across the US. Far too many advocates and policy makers are unaware of the quality and aesthetic appeal of manufactured homes. There is no doubt industry has made great strides to modernize the energy efficiency, the design and the value of the homes. Quite simply, the CFPB’s report underscores the need for the financing to be modernized, as well. ##

    doug-ryan-cfed-posted-manufactured-home-living-news-industry-voices-guest-blog-mhpronews-

    Doug Ryan
    CFED
    dryan@cfed.org

     

     

    Related Links:

    1) – MHI's Response to CFPB's Report (Note, the MHI link includes the full CFPB report as a free download)

    2) – MHARR's Response to RV legislation and CFPB's Report on Manufactured Housing

    3) – CFPB Report on Manufactured Housing Signals Areas of Future Concern

    4) – Manufactured Housing Institute Responds to Doug Ryan-CFED commentary on CFPB report on Manufactured Housing Finance

    (Image credit: Corporation for Enterprise Development (CFED logo.)

    (Editor's Note: As with any opinion column, the views expressed by Mr. Ryan are his own and/or those of the organization he works for, and should not be construed to be the views of MHProNews or our sponsors. Other viewpoints on this or other industry topics are encouraged.

    MHProNews plans an Industry in Focus Report using extensive comments from a range of industry professionals on this topic. Watch for it mid-week at the news/reports module link above!)

    2013 CFED-I’m Home Retreat Snapshot

    October 20th, 2013 No comments

    Following a retreat for Next Step and its Partners, I was privileged to participate in the CFED I'm Home Retreat in Denver. Imagine a “for profit” mind immersed in a “non profit” retreat. It would have been easy to allow your head to spin if the topics discussed were not so familiar.

    The Retreat was fully immersed in the role manufactured housing (MH) could play for the working poor as an answer for initial and replacement housing.

    George McCarthy, from the Ford Foundation, gave some great statistics about those living in MH and the percentage of those populations in communities. These stats further magnified the continuing role MH communities’ play in general housing and manufactured housing specifically.

    However, energies soon were redirected to the discussion on funding, both for inventory and retail; appraisals; placement, yadda yadda yadda.

    As Barry Noffziger, from CU Factory Built Lending suggested – if you close your eyes, you could have sworn you were in any MH association meeting. The concerns and challenges seemed to be the same as the “for profit” side of the industry. The plea was to unite in order to facilitate change.

    It was an interesting juxtaposition to find myself in the middle of a segment of the industry I knew/know little about; but yet I could appreciate their passion.

    Their energy was unbelievable. Positive – glass seemed to be half full everywhere I looked.

    Paul Bradley from ROC was there and talked about their success and plans for the future. 

    There was a testimonial about efforts to re-house victims in a MH community affected by Hurricane Sandy; flood victims in Colorado and other locations.

    Architect Bruce Tolar, of the Katrina Cottage fame, provided an overview on the lessons learned and how the Cottage is morphing for long term housing solutions. It was noted that long after the national news crews left the Gulf area, there are still victims of Katrina struggling to cope with inadequate housing – 8 years following the hurricane – FEMA gone, almost everyone else as well.

    chris-nicely-posted-on-mhpronews-comHeck, that was only the first day and sadly, I had to leave. How often do you leave a meeting saying, “I can’t go, I want to hear and learn more."

    Curious, the effort in the room was focused on the resident/owner and how MH can deliver more value and provide life with dignity. This, for a segment of the population most writes off as un-qualified buyers.

    It was refreshing and left me wanting to know more about what I could do to help. Hopefully, I will get the chance. ##

    chris-nicely-posted-on-mhpronews-com-2.jpgChris Nicely
    9052 Legends Lake Lane
    Knoxville, TN 37922
    865.385.9675
    cnicely929@aol.com  

    Manufactured Housing Institute and Consumer Groups Urge CFPB to Change Loan Originator Guidelines; Support Builds for H.R. 1779

    September 15th, 2013 No comments

    In a communiqué to MHProNews, MHI's Vice President of Regulatory Affairs, Jason Boehlert shared the following report to Industry members.

    MHI and Consumer Groups Partner to Revise CFPB Rules

    On September 5th, MHI joined with a coalition of consumer advocacy organizations, including the Center for Responsible Lending (CRL), Corporation for Enterprise Development (CFED) and National Consumer Law Center (NCLC), to jointly urge the Consumer Financial Protection Bureau (CFPB) to amend key mortgage finance rules and preserve access to credit in the manufactured housing market.

    Since May, key MHI members and staff have been working with representatives of these three consumer groups to develop a compromise on rules related to loan originator compensation and classification, and HOEPA High-Cost Mortgage triggers – issues that are addressed in the Preserving Access to Manufactured Housing Act (H.R. 1779).

    manufactured-housing-institute-logo-posted-mhpronews-industry-voices=guest=blog

    Negotiations have been taking place through the assistance and participation of majority and minority staff of the House Financial Services Committee and Senator Sherrod Brown, who serves as Chairman of the Senate Banking Subcommittee on Financial Institutions and Consumer Credit.

    As a result of the negotiations, MHI and the three consumer organizations have agreed to jointly ask the CFPB to clarify and amend its rules in two key areas:

    Loan Originator Compensation — for purposes of classifying a manufactured home retail salesperson as a Loan Originator, urge the CFPB to better clarify that as long as no incentive is provided or offered by the retailer or the lender to the individual salesperson to steer the consumer to a certain lender or loan product, then the salesperson should not be considered a Loan Originator.

    While the CFPB has issued recent rules removing the manufactured home sales price and any sales commission paid to a sales person from points and fees calculations, an individual salesperson can still be classified as a Loan Originator by performing certain activities (i.e., taking an application, and referring a consumer to a lender). This activity would then classify the retailer as a mortgage broker. Both designations carry significant requirements and liabilities, most notably supervision by the CFPB.

    HOEPA High-Cost Mortgage Triggers — consumer organizations have agreed to join with MHI in urging the CFPB to reopen its previous final rule on HOEPA. As a result of the significant dialogue that has taken place between the two sides, the consumer organizations have agreed that a significant reduction in access to credit would result in January 2014 (when the rule goes into effect) for the manufactured housing market unless the CFPB modifies the High-Cost Mortgage triggers. While the two sides have not agreed to a specific number, the willingness of the groups to push for the CFPB to reconsider their prior rulemaking is significant.

    MHI and the consumer organizations will continue to meet with the CFPB on a joint basis in September on HOEPA issues. Pursuing a strategy of engagement with consumer groups provides the industry the opportunity to underscore the broad impact of CFPB rulemaking on consumers and the industry. In addition, it will provide a more rapid resolution of the industry’s concern when compared to a potentially protracted legislative battle over reopening the Dodd-Frank Act.

    However, it is important to note that as the industry gains ground with the CFPB and the consumer groups, Congressional support for the H.R. 1779 continues to build.

    Co-Sponsors to H.R. 1779 Grow

    During the month-long Congressional recess, more than 20 U.S. Representatives added their names as co-sponsors to H.R. 1779. Currently, nearly 70 Representatives have co-sponsored the measure and support continues to grow. MHI thanks its members and the national network of state associations for their hard work in urging Representatives to co-sponsor this important legislation (to view a current list of co-sponsors, click here).

    As has been previously mentioned, provisions of H.R. 1779 were included in GSE reform legislation (PATH Act; H.R. 2767) that was approved by the House Financial Services Committee and MHI staff continues to work with committee staff to seek an opportunity to move the legislation separately.

    While the CFPB has provided some key relief in recent rulemakings to the manufactured housing industry – with respect to appraisals and the calculations of points and fees – work still remains to be done to amend HOEPA triggers and the Loan Originator definition to better represent the needs of the manufactured housing market. Absent regulatory relief, statutory change is necessary.

    The industry is asked to continue its outreach efforts to U.S. Representatives. Urge them to co-sponsor H.R. 1779. For more information, click here to access MHI’s action alert. ##

    jason-boehlert-mhi-manufactuired-housing-pro=news-.pngJason Boehlert
    Manufactured Housing Institute (MHI)
    Vice President of Government Affairs
    1655 North Fort Meyer Drive
    Suite 104
    Arlington, VA 22209

    MHI members can contact Jason Boehlert at jboehlert@mfghome.org or (703) 558-0660.

    (Logo image credits to their respective organizations. Photo credit of Jason Boehlert, MHProNews.com)

    (Editor's Note:  Consumer groups did NOT in fact get on board for HR 1779, as we editorially observed in this blog post here.) 

    Dodd-Frank Congressional Hearing – Lost Opportunity?

    June 20th, 2011 No comments

    Dear Doug, George and Tony:

    Because of your keen interest in this issue, We thought that you might be interested in the below Press Release regarding a June 16, 2011 congressional hearing on the “Impact of Dodd-Frank Regulations on Jobs and U.S Competitiveness.” The hearing, according to the Release, is a reflection of “widespread and growing concern that the Dodd-Frank Act with its 400 new regulations will lead to industry capital and jobs leaving the United States.”

    Given the fact, as Doug so correctly pointed out in his recent open letter to CFED’s Kathryn Goulding, that Dodd-Frank, “without alteration will … eliminate the availability to finance [manufactured housing] loans lower than $78,000” when the HUD Code market averages $60,000, we were wondering whether anyone submitted, at the very least, written testimony for this hearing on behalf of the industry’s finance companies, retailers and communities? If not, that failure, in itself, illustrates the need for a separate national post-production industry association…and if yes, it should have been widely circulated for further publicity and a second bite of the apple with other members of Congress and Washington officials.

    While it is true that the focus of the in-person testimony at this particular hearing related more to international regulatory disparities, the fact remains that given the potential damage that Dodd-Frank regulation could do to the industry, with its corresponding impacts on economy, jobs and competitiveness in the heartland of the United States, this matter (i.e., elimination of a whole class of affordable housing for moderate and lower income American families) should be highlighted and new markers established with Congress and other officials in Washington at every step, such as this hearing. The post-production sector and its national representative, need to be taking advantage of every conceivable opportunity and every possible forum (particularly a direct Dodd-Frank hearing, like this) to expose the plight of the industry and its consumers, and the need for a remedy from Congress. Needless to say MHARR fully supports any such action.

    Thanks,

    Danny

    Danny D. Ghorbani
    President
    Manufactured Housing Association for Regulatory Reform
    1331 Pennsylvania Ave. N.W. Suite 508
    Washington, D.C. 20004
    Phone: 202/783-4087
    Fax: 202/783-4075
    Email: DANNYGHORBANI@AOL.COM


    Financial Services Committee of the U.S. House of Representatives

    Press Release
    Financial Services Committee to Examine Impact of Dodd-Frank Regulations on Jobs and U.S. Competitiveness
    WASHINGTON — The Financial Services Committee will examine the international implications of the Dodd-Frank Act on U.S. economic competitiveness during a hearing on Thursday.

    “There is a widespread and growing concern that the Dodd-Frank Act with its 400 new regulations will lead to industry, capital and jobs leaving the United States. This is a concern that many of us on the Committee have expressed repeatedly,” said Chairman Spencer Bachus. “Our hearing will examine the regulatory disparities between the U.S. and other nations and how that could put American companies at a competitive disadvantage and harm our economy.”

    The Committee will specifically look at four crucial areas where divergent regulatory approaches taken by the United States and the rest of the world could damage the U.S. economy and the ability of financial institutions to compete against their foreign counterparts: capital and liquidity requirements; regulation and oversight of “systemically important financial institutions”; derivatives requirements; and a total ban on proprietary trading.

    The hearing, titled “Financial Regulatory Reform: The International Context,” will begin at 10 a.m. on Thursday, June 16 in room 2128 of the Rayburn House Office Building.

    This will be a two-panel hearing with the following witnesses:
    Panel I
    Sheila C. Bair, Chairman of the Federal Deposit Insurance Corporation
    Lael Brainard, Under Secretary of the Treasury for International Affairs
    Gary Gensler, Chairman of the Commodity Futures Trading Commission
    Mary Schapiro, Chairman of the Securities and Exchange Commission
    Daniel K. Tarullo, Governor, Board of Governors of the Federal Reserve System
    John Walsh, Acting Comptroller of the Currency, Office of the Comptroller of the Currency
    Panel II
    Stephen O’Connor, Managing Director, Morgan Stanley, and Chairman, International Swaps and Derivatives Association
    Timothy Ryan, President & CEO of the Securities Industry and Financial Markets Association
    Hal S. Scott, Nomura Professor and Director of the Program on International Financial Systems, Harvard Law School
    Barry L. Zubrow, Executive Vice President and Chief Risk Officer, JPMorgan Chase & Co.
    Damon A. Silvers, Associate General Counsel, American Federation of Labor and Congress of Industrial Organizations

    Open Letter to CFED regarding Dodd-Frank and its impact on affordable Manufactured Housing

    May 24th, 2011 No comments

    To: Kathryn Gwatkin Goulding
    Cc: CFED Federal Policy

    Kathryn,

    I am receipt of CFED’s newsletter earlier today in which praises were heaped upon the Dodd-Frank Bill and its related Consumer Financial Protection Bureau. Analysis of the bill by numerous manufactured housing industry financial services consultants have concluded that without modifications, this bill could destroy our industry which is currently only hanging on by a thread anyway.

    The Dodd-Frank Bill is far too typical of Congress’ meddling with our system with devastating effects on lower income families. While boasting about protection for consumers, the results of the bill without alteration will be to eliminate the availability to finance home loans lower than $78,000. Since our loans average about $60,000, more than half of our market will be eliminated. Those unable to get loans will be the ones at the lower portion of our client base. I don’t think these wanted Congress to legislate them out of the ability to purchase a home. Rather than promoting the infallibility of the Dodd-Frank Bill, CFED should be rallying to support the changes needed to protect the lowest income home purchasers in our nation. Just because they are low income, they should not be forced out of the ability to purchase a home. As I assume you are aware, our industry is already at the lowest level of shipments since record keeping began in 1961. Unmodified, the Dodd-Frank Bill will most likely destroy any hope for a recovery. The sad thing is that the death of the industry will not result from the Free Enterprise rejection by the market; it will be the result of an ignorant Congress legislating low income consumers out of the ability to borrow the funds necessary to finance their home. Of course, Congress did the same thing to the US light bulb manufacturers so maybe we should have seen it coming.

    Please note the comments below in a column written by industry expert and Industry Person of the Year, George Allen. Please join our industry to encourage Congress to make the modifications necessary to preserve the ability of our lowest income homeowners to achieve their goal of homeownership. I appreciate the efforts CFED has taken over the years to protect low income families. Removing their ability to purchase a home will not be to their benefit.

    George Allen–
    Dodd-Frank Fallout. Geesh! This bill isn’t even law yet, and finance-related businesses are closing, simply to avoid having to put up with the more onerous of its proposed/planned regulations. Already, ‘former employees,’ perhaps even potential borrowers, are paying the price for what, to many of us, appears to be excessive regulatory reach into the financial sector. Here’s the plaint of one blog flogger (i.e., reader) writing to us this past week…
    ‘Dodd-Frank forced us to close our mortgage company in ___________ , and lay off several employees. Reason? Our capitalization with _______________ (a major bank) as our JV partner, was slightly in excess of $1,000,000. We were not a broker, but a direct lender, using the bank’s money. Under Dodd-Frank, unless you have a ten million dollar capitalization, you get classified as a broker. And as a broker, you have additional disclosures, the required language of which pretty much scares your customers away to a direct lender. So, we are out of business. Multiply that many times, in every community in America. An apt example of ‘the law of unintended consequences,’ as well as job and prosperity killing legislation!’ (lightly edited. GFA)

    …the Dodd-Frank bill is maybe the ‘final nail in the coffin of chattel finance,’ where manufactured housing is concerned? Whereas the necessity of added fees will necessitate a minimum manufactured housing loan of $78,000.00, to simply ensure the return of basic and added fees to a chattel lender. And outside certain high-priced local housing markets, how many times do we see manufactured home loans, especially on resale homes, in excess of $78,000.00? # #

    Thanks,

    Doug Gorman
    Home-Mart, Inc.
    9516 East Admiral Place
    Tulsa, OK 74116
    800-364-4663 Toll free
    918-835-0500 Office
    918-835-8146 Fax
    918-250-6867 Home
    918-640-1357 Cell
    doug@homemart.us
    www.homemart.us

    Editor’s Note: Please click here to read the CFED document.