- Could MHARR member manufacturers have confidence in such a proposed restructure?
- Could retailers and others have confidence in a proposed restructure where they are not even mentioned?
There is a lot to say about what has gone wrong with our country and our Industry. We will begin ‘at the top,’ with our Chief Executive, President Barack Obama.
What’s up with Obama’s recent bus tour?
I’m no fan of the prior president, but say what you will about President W, when he took a similar bus trip to President Obama’s, W used campaign dollars to pay for it. Where is the “watchdog” media? Why no hue and cry when the administration buys millions of dollars of Canadian buses so President BO can tour in style on the taxpayer’s dime?
What’s up with all that?
Isn’t it ironic that BO tours campaign style after lecturing millionaires and billionaires about private jets and corporate perks? Or is that rhetoric just a way of getting the votes of middle America and ‘the little people?’
Do you like ‘divide and conquer politics? To me, it is plain wrong. Talk about issues, talk records or about facts. But don’t pit one group against another.
I need to be clear that W vacationed considerably more than BO. But W went to his ranch or Camp David, etc. But to add irony to injury, on the heels of all this bad economic news, BO is in Martha’s Vineyard – the haven of the elite – now?
Even left wing commentators see this vacation in the New England playground of the rich and famous as a problem.
They say the emperor has no clothes. Well, we have no emperor, but a president and his wardrobe looks just fine.
Ascendancy and Dependency
It is the party of dependency that is still in ascendency.
Or at least still in high office…
…dependency is a major voting block today.
Be it government labor unions, federal jobs or those on government assistance, it is an issue. We have to put people to work, not get them used to no work. We do need federal and other government jobs. But we can’t give everyone a job regulating someone who is working to produce a product or a service that keeps America’s wheels turning.
If we do not change our ways federally and locally, we will look like rioting old England some day, because we can’t afford to keep adding to our debt and taking on more programs that fail to foster independence.
While we have plenty of dependency programs, meanwhile, we have
I didn’t favor W taking us into Iraq, nor do I favor BO taking us into Libya. Even if we ‘win,’ what have we won in either case? We spill American blood and treasure, for what? We can’t be the world’s cop, and we can’t have wars for the sake of foreign oil, etc.
Let’s drill and do energy on U.S. soil and off U.S. shores, as safely and prudently as possible. Think about the major jobs creation potential.
Private enterprise can pay for it all without federal dollars. Let business people do business in America again.
Another Recession, what’s up with that?
The media speaks of double dip recession. What’s up with that phrase?
Did anyone notice that the ‘great recession’ never ended? Did you notice that the housing markets still suffer, and Keynesian/Euro socialist economics just added trillions to our debt without giving us a stronger economy?
No jobs. No stimulated business. Tougher lending. Very little respect overseas. Where is the change we can believe in? Or was that supposed to mean the pocket change we have left after taxes?
Third part candidate George Wallace once said there wasn’t a dime’s worth of difference between the two major parties. Thus Wallace favored what some have for years, a third party to bring America back. But Ronald Reagan had it closer, we don’t need a third party, but a rejuvenated second party.
That means we don’t need Rino Republicans, Republicans In Name Only. To me, W was a Rino, socially conservative, but nearly as much a man about big government as BO is. W helped give us that darn bail out of the bankers. W took us into two wars with no end in sight. W’s dad may not have “finished the job” in the first Gulf War, but he had the smarts to get in and get out.
We need business friendly independents, Democrats and Republicans.
Businesses create jobs. Jobs are what American’s need, and then they can start buying houses again!
Speaking of jobs, how about creating 20 million new ones?
I’ve read the same reports you have; that there are two trillion dollars of investment money on the sidelines – actually overseas – that could be brought back to the U.S. In short order.
But that 2 trillion fled America due to regulations and tax policies. Do we have the political will to bring those trillions back?
Think about what Two Trillion Dollars we don’t have to borrow, or write down, would mean to our country right now. If every $100,000 invested created only 1 American job, that would mean 20,000,000 jobs.
Think: 20 million people off aid, off food stamps, off unemployment or other government programs. 2o million more taxpayers. Think 20 million people less dependent, means we would be that much closer to a balanced budget!
We better find and support candidates in whatever party who know how the free enterprise system works, because creating jobs by supporting business is what we should be about.
Free Enterprise, not Keynesian/Euro socialist economics, is what made America the land of the free and the home of the brave.
November 2012 is shaping up now. Who we support now for our state houses, or for Congress, the Senate and the White House will be on the ballot 15 months from now.
Personally, I’ve contacted my senators and representative and made my feelings known on economic and social issues. But I will also make them known on the path to election 2012.
Give the man his props
One thing that our recently bus touring and now vacationing BO has done is give us an executive order we can believe in. With all due respect to Marty Lavin, Danny Ghorbani was the first to bring it to our Industry’s attention. We speak of Executive Order (EO) #13563, similar to President Clinton’s issued in 1993.
MHMSM.com posted EO #13563 months ago, that requires an examination of regulatory impact and its benefits.
MHARR is right. HUD’s budget has grown, while our industry shipments have shrunk. What’s up with that fact?
What the president – at least on paper - has done is give us EO#13563 which could hold HUD and other regulators accountable. Now will our national associations use that to our Industry’s benefit?
The Fall Congressional hearing on Manufactured Housing
Who do we have in DC “helping us” in the planned fall Congressional hearings on our Industry? Congressman Barney Frank. What’s up with that?
Let’s see. Barney helped give us the SAFE Act. Barney also gave us part of the name of the bill that in his: Dodd-Frank.
So do you feel safer or dodd-franked?
With friends like Barney, does our industry need any federal enemies?
Who is watching how our industry PAC money is spent? Is this the type of anti-business candidate we need to support?
Where is that change we can believe in? Or did I drop that change the last time I filed my quarterlies?
One of the best meeting planners around, but…
I asked Tony Kovach why George Allen’s Roundtable was not on the MHMSM.com calendar. “George isn’t an association, and he opted not to pay for an ad.”
Maybe there is considerable momentum from last year’s event that MHMSM.com did promote. I noticed that Allen is reporting more state association executives coming to the Roundtable this year. State execs are often ‘comped’ for coming to an event. George is one of the best self-promoters the Industry has seen in the past 2 decades. I’d want state execs helping me promote an event of mine too. Nothing wrong with it, a common practice.
In the manufactured home communities world, Allen’s Roundtables are unmatched. Allen gets some fine speakers and topics in. They are informative and enjoyable.
However, I can’t always agree with George Allen’s commentary, live or in his columns here or in his own publications. Let’s parse some of his recent ones for a few moments.
I understand and agree with George that MHI doesn’t seem to have a plan for our Industry’s recovery. What’s up with that fact? I can see why the natives are restless in the NCC, even with Lisa B getting appointed.
George is spot on that MHI is failing to do half of what an association is called to do – protect and promote.
But George’s bashing of Danny and MHARR misses the mark. Why?
Because MHARR is an association for independent Manufacturers. MHARR don’t get paid to represent communities or lenders or suppliers. MHARR doesn’t represent retailers, which if you ask retailers like Doug Gorman or Dick Moore, MHI doesn’t seem to do such a hot job for them either.
George, the point is that MHARR can’t be faulted for focusing on what its members pay MHARR to do, namely, work on regulatory issues. So George, if you want to fault Danny, fault him for something that group is paid to do. At least MHARR has stated publicly they support the ‘post production’ sector (MHARR code words for MHI) in their efforts to modify Dodd-Frank, SAFE, etc. I’ve not seen any similar effort from MHI back towards MHARR. If it exists, it is behind the scenes.
I also agree with Marty Lavin that we better watch more what people say than what people do. We better watch results, because words alone can be cheap.
Or words can costly, depending on how you look at it.
Industry Marketing and Image Campaign
Speaking of MHI and the Industry image campaign…
…I’ve seen the plan Tony, IMHA’s Mark Bowersox and others have put together. In a word, brilliant.
In my mind, they need to consider a different name, but for now they are calling it the Manufactured Housing Alliance and Phoenix Plan. Their plan navigates the key political issues that our industry has faced that has kept us from moving ahead.
We keep reading from MHI the statistics about our dropping new home shipments. This gets back to the dual role that an association is supposed to have, protect and promote.
Where is MHI on this MH Alliance/Phoenix Plan effort to turn around our image, marketing and sales results?
By contrast. I see John Bostick’s name on the page in favor of the MH Alliance/Phoenix Plan. That makes me want to order some Sunshine Homes and get others to do the same!
Good for MHARR’s Chairman, who did not endorse it on MHARR’s behalf, but Mr. Bostick has obviously taken the time and had the guts to publicly say, hey, this can work.
Which leads to the questions:
> Where are the MHARR members or Danny on this plan?
> Where is MHI on this plan?
Marty Lavin on Danny Ghorbani
I’m the first to agree with Marty that Danny needs to polish up those lobbying skills. In fact, let me take Marty’s points a step farther. As I personally see it, and others may disagree, Danny has three options:
Danny, retire? What would happen to MHARR without Danny? What’s up with that idea? Can you even say MHARR without saying Danny G’s name?
Yes, you can.
Attorney and MHARR VP Mark Weiss is a good man. Mark knows the law, can be reasoned with and Danny has prepared him to take the helm at MHARR, when the time comes that Danny decides to retire or when MHARR members make that decision.
For example, MHARR could bring in a new associate, give Danny a nice gold watch, and a one year transitional consulting agreement. The independent factories that support MHARR can save money. As or more important, they likely can get more done and advance their cause in DC with HUD, Congress and other regulators.
The timing is right for a change at MHARR. Danny, don’t take it the wrong way, you are a smart guy and know the HUD Code as well as anyone in the manufacturing side of the Industry. But in my personal opinion, it is time to change your ways for the better or you better retire.
The best suits and fine meetings
Danny has some of the best suits in DC that our Industry can brag about. Danny and MHARR are spot on with some key issues. But you can be right, and still do things in a way that turns people off.
But give the man his props, Danny is right about MHI meeting,
after meeting and
…where is the MHI plan?
But then, Danny – if you stay – you and MHARR should then walk the walk and have an action plan of your own. Not a some day, or five year plan, a let’s get it done now plan.
Perhaps John Bostick’s public move supporting the MH Alliance/Phoenix Plan will inspire others of stature to make their own public statements or just help launch the program.
But at some point, we need to get past meetings, and get to doing. 46,000 shipments. We are now down about 88% from our post HUD-Code high in 1998. How much lower can we go and still have an Industry?
The Numbers on MAP
I like abbreviations. Let’s call this plan of Mark’s and Tony’s MAP for short, because this MH Alliance Phoenix can be our road MAP to the future. Maybe we can get Tony and Mark to come up with a better name. But in the mean time, MAP it is for me.
I asked Tony to give me a projection on what he thinks MAP can do. His answer? First year from the launch date could double shipments without a need for hurricane season (no need for FEMA orders).
The next year could double it again. That would be roughly 92,000 shipments in year 1. Then 184,000 shipments in year two.
Take a look at the MAP if you haven’t already. If you have a better plan, why not share it? But if not, get behind the plan that is out there being discussed.
I’m told that MAP can be up and running in short order. We can do MAP, with no waiting for federal or state action!
Doing the Math, my Math not T’s
Tony has his math, I have mine.
Let’s say MAP was launched, and then MAP raised shipments back to 75,000 the first year. Let’s further say, 1/2 of the increase went into communities.
Would you give $75 per location to boost sales $1.45 Billion and create about $48 million in new communities revenues?
If not, please go back to 5th grade math. To me, this spells a good deal.
Let me stress, these are my numbers, not T’s or Mark’s. But it tells me why they and others are working to see this plan happen.
I’m not without experience in dealing with personal property lending. While he wasn’t talking about just lending, I agree with Chad Carr’s recently published statement about MAP. The MH Alliance/Phoenix Plan is the only plan I’ve seen that gets to the heart of fixing chattel lending for our Industry. MAP provides solutions for image, lobbying and other practical issues too. It dares to be bold, without trying to step on any industry group’s toes.
If your chattel lender has not yet seen this, she or he better do so! This can help us cut our repos losses dramatically.
It will help our customers – manufactured home owners – dramatically too. That will in turn attract more customers, and more credit worthy ones.
Manufactured housing lenders need to see our losses cut. Because that panel of lenders at the MHI Congress last April were correct. A repo can cost 50% (or more) of the loan balance. There are so many dark clouds that hang over personal property lending for manufactured housing right now, we have to have solutions if our Industry will ever advance.
In fact, our survival depends on it.
I asked Tony specifically about people who have and have not seen MAP. T won’t comment about those who haven’t shared a public statement. I can respect that, but it does leave us guessing.
So someone needs to ask Marty Lavin or Dick Ernst where they are on this. Have they seen it? What is there take? It is obvious that Ken Rishel has come out for it, big time, in his own newsletter and on MHMSM.com too.
Come to think of it, where is George Allen’s name on this subject? Didn’t he say a few months ago, we needed an image campaign? What’s up with that?
We could go through a list of industry leaders and say, what about you? Where are you on this MAP subject?
If you are for it, why not say so publicly? If you oppose it, why and then propose your own alternative! Mark, Tony and those working on this want to see consensus. I appreciate that, but I’d add that we can’t afford to debate stuff forever. We need to move ahead, and pronto.
If we do not start advancing, more factories, more retailers and more communities will fail. It is simply 5th grade math.
State and Communities Association leaders
Given that a pair of state association leaders have already publicly stated support for the MH Alliance and Phoenix plan, it is reasonable to think others have seen it too. We need to watch and encourage this plan at the state level.
Because let’s be honest, the states are where it is at. All politics are local, and your business happens at the state and local level.
Last year, we saw some state execs who took a leadership role to get things happening at the federal level. We need to see that again, and we need to see that on MAP or their best alternative to it.
A pimple on an elephant’s bottom
We’ve heard this expression at meetings and coffee tables. I admit it sadly fits the influence our Industry has politically in DC today. We need to be working tea parties to get the party of jobs, business and growth moving ahead. We need to hold the feet of those who say they will change DC for the better to the fire, and get the gold of jobs and rising housing back to work building the U.S.A.
We have lost our nation’s AAA credit rating. Debt piles up, what do we have to show for it? Where are the jobs? The lending? The recovery? What did we bail out anyway? Who benefited from all that taxpayer funded largess?
We saw some amazing upsets at the midterms, and I think we can see more if we plan now for the best candidates and then mobilize for the general elections.
It is frankly another good reason to learn and get behind the MAP. We will increase our influence at the state house and in Washington when our consumers are visibly supporting us in sizable numbers.
Let’s work and earn the support of our communities’ residents and home owners/customers! Then we should make sure we continue to deserve it. Without happy customers, we are as doomed as if HUD bureaucrats or others would just shut us down.
If I boiled this down, it would be this. We can’t have something for nothing. TANSTAFL = There is no such thing as a free lunch. Someone always pays.
We better work for truly positive change, or we will be left with pocket change.
We better look at and support a plan that can move us ahead. I vote for the MH Alliance/Phoenix Plan. Or we will suffer the fate of the buggy whip makers.
I shop at WalMart no more than I have to, because I believe in supporting the smaller and more independent business women and men out there. They are more like me. They want to serve me, and I in turn want to support them.
We better support the HUD Code builders, and they in turn, better support us too.
Talking and Doing.
Before we look at any other emperor who also lacks clothes, let’s close for now. Talk is fine, but let’s follow talk with do.
I want to thank those of you who have written. Please do not think me rude, but for now…
…I hope you understand that some things need to be said that have gone unsaid too long.
More next time.##
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I get “The Journal” monthly, the Jim Visser published magazine that appears to be the sole remaining print manufactured housing periodical. Others, including the much beloved Manufactured Housing Merchandiser, dropped by the wayside in the recent past, as advertising support fell off. Take HUD Code home shipments from 372,800 in 1998, and let them free-fall to some 50,000 in 2010, and that 86% drop annihilated much of an entire industry. We see the results about as everywhere.
I read The Journal regularly, reading some articles carefully and skimming others of less interest to me, but I look at all of them. Note that all of the writers therein are either executives at MH trade associations, or consultants. The tradeoff for the publication is a plentiful supply of written material for free, which they sandwich around their advertising. The writers, mostly consultants, get no pay but are happy to write the pieces to highlight their acumen in their area of expertise, sometimes leading to paid consulting assignments.
We also get some “infomercials” from paid advertisers. They buy an ad and the periodical allows them to write a “puff piece,” often nothing more than a glorified press release. No worries mate, The Journal is not the Wall Street Journal and no one expects it to be.
All the materials therein provide information, which is what advertising is meant to do. The reason Jack uses Enzyte after playing golf is that it makes him a “bigger” man. Informative, right?
Read the articles written by a number of the regular contributors in The Journal or an online ezine like MSMSM.com, and you begin to have a feel for the person or organization producing these pieces.
As an example, both the manufactured housing trade associations, Manufactured Housing Institute (MHI) and Manufactured Housing Association for Regulatory Reform (MHARR) use the pages of The Journal and MHMSM.com to report their goals and positions on industry matters they deem important. It is also very obviously a recruitment tool for them.
And what can we glean from the decade plus of pieces there by the two national associations in The Journal?
The first thing we deduce is that MHI, through its last three leaders, strikes a measured approach to Washington matters. Being a collection of both home production and the dreaded “post production” segments, they come across as informed, conciliatory, and doing what they can to further the industry’s goals, as envisioned by a few large and powerful members, especially those who are heavy dues payers.
The MHI employee count has plunged in the last 10 years almost as much as industry home shipments, yet I do not notice that much fall-off in their accomplishments. This either says a great deal about the efficiency of the present crew there or the common occurrence in organizations to grow employees more than accomplishments.
On the other hand, MHARR has been, with a brief hiatus in the last few years, almost exclusively the venue for the HUD Code home producers. At MHARR “post production” seems like two dirty words. The HUD Code, the feared federal regulatory scheme of the late 1970’s, brought cries of “it will destroy the industry” before it’s taking effect. Since then, like the “Stockholm Syndrome” it has taken full control of MHARR, and their strong expressions in the pages of The Journal and everywhere else they’ll be heard.
One can only view it as a hate-love relationship with the HUD Code as interpreted, declared and attacked by MHARR’s fearless battering ram, Danny Ghorbani. Say what you will about Danny, he is knowledgeable about the HUD Code as no one else, and relentless in his pursuit of seeing it applied as he sees its meaning.
Danny’s problem, of course, is that not everyone sees it his way. I haven’t noticed MHI being quite so animated in its pursuit of “the Code.” Oh, I’m still waiting for Danny to complete the Manufactured Housing Improvement Act of 2000 (MHIA 2000) Subpart I mandates, his 10-year quest I think as yet uncompleted.
Anyone who has read the pieces by the national association heads here at MHMSM.com and elsewhere will have the feeling that MHI and MHARR are very different organizations. If I’m asked which is more effective I can only comment that neither has been able to stop the regulatory onslaught nor marshaled a unified approach to correcting the deficiencies of the Manufactured Buggy Whip industry. Their efforts have all been in Washington, where they all live and work. Other than the “Duty to Serve” inserted into the GSE mandates, I’ve seen little or nothing which would sell one more home, which should be the aim of the national associations, not the ease of home production.
Blocked weather radios?
Well Hells Bells, Boy, that saved $40.00 per home! Look how that saved $40.00 spurred the sale of homes!
The industry has a whole news media constantly telling the public of the danger of turbulent weather towards manufactured housing. So the battle against weather radios comes off in the media as lack of care for consumer safety by the MH industry. Instead, the weather radio, perhaps not the best weather Paul Revere, could have been taken by the industry and used to show how much MH cares about consumer safety in a lemons to lemonade move. The industry might also have supported proper installation and anchoring of homes. Those moves were fought everywhere, including Florida, where anchors were slammed down our craw. Who was the first to take credit for the very fine job anchored MH demonstrated after the numerous hurricanes in Florida? You tell me!
Waiting to See
But here’s the article I’m awaiting to see in MHMSM.com and in The Journal, by both organizations: Here is a list of the items we have accomplished in Washington, and elsewhere WHICH HAVE LED TO THE SALE OF x MORE HOMES AND MADE THEM A BETTER VALUE FOR OUR CONSUMERS. Wanna see that one? I sure do.
Perhaps it’s unfair to pick on the two national associations. They are both staffed with good people doing what they think is right for the industry. Maybe our expectations for their results are too high.
Could it be these national associations exist only to create and support networking opportunities between industry players and to inform of matters deemed to be important or interesting as it affects the industry? Long ago I came to that conclusion.
The starkest example of the inability of the national associations to really matter beyond information and networking occurred during the period of 2001-2010, especially in 2004-2008, as frequent attempts were made to “restructure” the so-apparent industry defects which were destroying industry sales.
For a variety of reasons, none of the grandiose measures proposed, vetted and formulated in writing came to fruition, as we saw our associations have no ability to restructure an industry. Only the marketplace has that ability, and it proceeds to do so apace. Note that shipments through June of 2011 were down almost 12.3% from last year. Let’s face it, we blew what little wad we had in Elkhart in June of 2010 when FHFA, the GSE’s regulator, told the industry plainly: Our Duty to Serve (DTS) the MH industry doesn’t extend to chattel lending, as the GSE’s already have enough problems without getting into new and potentially troublesome areas, where they have very limited expertise. So much for Duty to Serve and all the homes it would sell through new chattel financing from the GSE’s.
The associations did help get FHA Title I (Chattel Loan) reformed last year, after the program was long time moribund. First year loan volume in 2010 was hardly encouraging, but OK, put that on the list as an accomplishment, limited as it is.
The horse has left the stable on SAFE, Dodd-Frank, other regulations and Super Consumer Agency. Both national associations are actively trying to reform major portions of the laws to exempt MH retailers and others from the force of the laws and their regulations. I suppose a strong selling point by the industry can be the straightforward reputation MH has for integrity in the sale and financing of homes. (Ah, they may have to back off from that one.) I think instead they are going to use affordability of our homes and limiting consumer choices as reasons to exempt manufactured housing from the new regulations. That event, should it transpire, should turbo-boost new home shipments! Right?
Wait a minute. Those laws, bureaus and regs haven’t been in effect all during the explosive industry dismantlement since 1999, so even if the above laws do not take effect against MH they will only reduce the slide, and do nothing to increase shipments. Whoops!
Every month we read the numerous communiqués from both national associations. MHI seems the more measured with a range of information and an attempt to influence law makers and regulators with an effort to strike a balance between persuasion and facts. They do not seem to get much done, but then again, why should we expect the MH industry, a true 90 pound weakling, to get things done on SAFE, Dodd-Frank, and Super Consumer Agency when real powerhouses like the Mortgage Bankers and Realtors have had so little success. How, indeed?
Read one of the missives from MHARR and at first blush these beautifully structured sentences and paragraphs speak of power, passion, and a non-compromising attitude. I suppose the reality would be more palatable if not for the fact that this association is a loud-mouthed 90 pound weakling, but a weakling nonetheless. Their endless wrangling with HUD and others almost seems like that cartoon where Bugs and Elmer Fudd go to work every day, punch the time clock, spend 8 hours abusing each other, then punch out at day’s end and go home for a burger and a cold beer. It’s all a game.
And I don’t really blame the staff at MHARR, as they are employees who are guided by the officers and members of the association. It is they who foster this pugnacious attitude. If they have turned MHARR into a “wind them up and let ‘em pummel” HUD or whoever, it is because many in MH have this deviant thought that the “affordability” of the homes the industry produces allows them special prerogatives at the political table. What they do not apparently understand is that affordability of our homes is in the eye of the beholder, and in any event, loan defaults trump home affordability. The industry and their national associations make too much of “affordability” and the results show.
This would all be amusing, of course, if in the course of being a lobbyist, which MHARR is, it actually got things accomplished. Instead, we see a lobbying effort whose response from those they lobby is to roll their eyes about MHARR and call in sick when they are expected to visit.
MHI is conciliatory but gets little done and MHARR is pugnacious and gets little done. Maybe our expectations are too high for what each can and does accomplish. And certainly as shipments have plunged, so has the industry’s importance, PAC money and influence. Hang on to that affordability, it’s all we’ve got!
Currently, as the MH industry press explores the roles of the two national associations and whether another is needed, or whether there is any hope the existing two could and should merge, I’m bemused by all the attention to this concern. (Merger you say? Sure! Fool me once, shame on you, etc.) The role of each seems clear to me. MHI is the broad purveyor of consensus and civility, calling on uncaring bureaucrats who do little for them, but meet with them. MHARR is the pit bull, knocking on D.C. doors wherein frightened bureaucrats lie prostrate, with the door well locked. Don’t come in! One tries persuasion, the other intimidation. Both can work in the right hands and proper hands, but the limitations of each, as it applies to the industry, is clearer than ever.
At the heart of the matter is that mortgage defaults and loan losses trump home affordability and consumer choice. No matter the strategy employed by the two national associations, talking home affordability has its limits. In fact I daresay it is not affordability which drove bloated 1990’s MH shipments and sales. No, it was transaction ease, that is, it was easy during the Greenseco era to buy and finance a manufactured home. Home affordability to a degree remains, but transaction ease left, with the results we now see. I’m not sure how the national associations can react to that, for in order to re-establish transaction ease, someone has to take on some massive chattel loan losses. Any volunteers? Danny? Thayer? Anyone? # #
MARTIN V. (MARTY) LAVIN
attorney, consultant, expert witness
practice only in factory built housing
350 Main Street Suite 100
Burlington, Vermont 05401-3413
802-660-8888 802-238-7777 cell
web site: www.martylavin.com
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.
Danny D. Ghorbani
Manufactured Housing Association for Regulatory Reform
1331 Pennsylvania Ave. N.W. Suite 508
Washington, D.C. 20004
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:
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
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
Exclusive MHMSM.com Industry In Focus Report
The March 2011 IBISWorld report that cited manufactured home dealers as a ‘dying industry’ has made news inside and outside of the manufactured housing industry. MHMSM.com has contacted a variety of Industry leaders and personalities from coast to coast to get their comments. On-the-record comments have included national association leaders, as well as professionals in factory-built housing from the manufacturing, retail, communities and lending sectors.
Messages, comments and calls to MHMSM.com from manufactured home industry professionals dribbled in at first, and then gained in volume as publications such as The Atlantic and Business Insider covered the IBISWorld report. As an example of mainstream media coverage, a TV station in Houston reportedly called a regional firm to interview them about the developing IBISWorld story.
Derek Thompson, associate editor at The Atlantic, penned a commentary that included these words:
“At the center of a perfect storm of boomer burnout, a brutal recession,
and a rapidly changing industry, the mobile home retail market
could be the worst industry in America. Here’s why.”
“If I asked you to name America’s least fortunate industry, your mind might go to record stores, obliterated by on-demand apps; or photofinishers, left in the cold as digital cameras turn Americans into our own photo editors; or fabric makers, where business is booming … in Shenzhen, China.
“But when it comes to unlucky industries, it’s manufactured home (aka mobile home) retailers who really hit the trifecta. First they missed out on the housing boom. Then they felt the gut-punch of the recession. Now they might yet miss out on the recovery. That makes them America’s fastest dying industry, according to a new report from IBISWorld.”
Paul Bradley with Resident Owned Communities USA (ROC USA) was one of the first in the manufactured housing world’s leadership to publicly respond to this IBISWorld report. Bradley wrote a feature article for MHMSM.com that analyzed the IBISWorld report. Quoting from Bradley’s analysis:
“The (IBISWorld) report states ‘demand is dwindling’ and ‘sales are stagnant because the industry is not innovating, and that sales are likely to continue falling in the coming years.’ They go on to say, ‘Manufacturers have made cosmetics changes to manufactured homes, but they have not been significant enough to alter their life cycle stage.’ The report puts MH retailers in the ‘Industry stagnation’ category of declining industries.
“Are you kidding me? These are ‘deeply researched answers’?
“First, the headline clearly comes from their marketing division as a means of grabbing headlines. The research is not about a dying industry but a declining industry segment – one of two long-standing distribution channels in the business.
“With MH shipments in 2010 at 50,000 or 20 percent of 2000 levels, it’s not news that retailer revenues over that period declined. On that data, I’m surprised establishments are not down more than 56 percent. It suggests that the segment has excess capacity and additional closings are likely.
“Most surprising to me is laying the blame at the feet of manufacturers on the issue of design! From a ground-level market vantage point, that’s misplaced.
“The industry’s great declines came about as a result of, first, an industry-created chattel collapse where the seeds were sown in run-up to the 373,000 shipments in 1998. The collapse, and the repossession overhang which followed, began the decline like a skilled boxer’s well-placed left jab.
“The right overhand came next in the form of aggressive sub-prime and predatory lenders in the site-built market. In that run-up, traditional MH buyers – who were harder to finance for MH as a result of the chattel collapse – were lost to site-built housing in an eerily familiar boom market.
“Dazed by the right hand blow to our collective heads, the left to the body that has people reeling now is the regulatory reaction – the SAFE act, etc. – to the clearly consumer-eating lending practices of the last decade.
“The results of this three punch combination are declines of the magnitude widely reported and felt, and like a good whack, the pain lasts a while.
“Innovation in housing design, however, is not the industry’s chief failing.
“For those of us in the community market segment, in fact, innovation in new homes is a small issue – not a non-issue but a mere shadow of the aforementioned home financing issue. In fact, we are seeing demand for replacement and in-fill homes but only where we are able to arrange decent home financing. People want more efficient homes and the cost savings with new EnergyStar homes can be dramatic based on buyers with whom I’ve spoken.”
(Editor’s Note: The complete analysis by Paul Bradley can be found at this link.)
Other commentary in the form of articles proposed for publication, private and public comments followed. Thayer Long at the Manufactured Housing Institute issued this email as part of his response:
“State Execs & MHI Board:
“A very well articulated response to the IBIS report from last week by Paul Bradley which was just posted on www.MHMSM.com.
“I’d also just add that the sentiment at the Tunica Show, the Louisville Show, and the expected strong turnout at the Congress & Expo and the Tulsa Show and York Show later this month certainly don’t indicate this industry is going anywhere.
“Tony/Paul – I hope you don’t mind me sharing. We’ll see you in Las Vegas. Thanks for your support.
MHMSM.com spoke with Danny Ghorbani at the Manufactured Housing Association for Regulatory Reform (MHARR) and to Thayer Long at the Manufactured Housing Institute.
Danny Ghorbani stated in a telephone interview that his comments were not the official position of MHARR, but represented his own views on the IBISWorld report and related.
Ghorbani stressed that the IBISWorld report represented the “failure” of “the post-production sector of the Industry” [meaning, MHI] in “serving that segment of its membership.”
The MHARR official then referenced two previously published documents that do represent MHARR’s official position, which were previously published on MHMSM.com in August and October 2010. These MHARR Viewpoint articles called for ‘the post-production segments’ of the manufactured housing industry to form their own national association; a thinly veiled vote of no-confidence from MHARR towards MHI.
MHMSM.com spoke extensively with Thayer Long at the Manufactured Housing Institute (MHI). The typically soft-spoken Long was quick to respond.
Long was at times tongue-in-cheek, at other points direct in his comments about the IBISWorld report and Ghorbani’s often pointed comments on the matter. It should be stressed that Long’s comments, which follow, should be viewed as his own, and not necessarily reflective of the official view of MHI.
In an exclusive interview with MHMSM.com, Long shared the following thoughts:
“If it is a dying industry, then ok, then I guess I quit! And if Danny wants to blame it on us [MHI], okay, what else is new? … I am still struggling to figure out what he (Danny Ghorbani) is doing right now. Name one thing that he has accomplished … in the past three years? What has he accomplished…? I would love for you to think about that and get back to me. What has he accomplished? We [MHI] win and lose some battles. But at least we try. We have accomplished some things. Except, except, except… [MHARR]…nothing….
READ THE FULL INDUSTRY IN FOCUS REPORT
Attached for your information and review is a copy of a Executive Order regarding federal regulation just issued by the White House on January 18, 2011. The Order, released in conjunction with a companion Wall Street Journal article by the President on over-regulation, marks a major policy shift by the Administration that has implications for manufactured housing as a federally-regulated industry.
In fact, it appears this Order almost could have been written with the HUD Code manufactured housing industry in mind. Its focus is on promoting the type of fair, reasonable and open regulatory environment that the HUD Code industry needs to thrive while serving consumers of affordable housing. Among other things, it states, as Administration policy, that the federal regulatory system, while protecting health and safety, must also advance “economic growth, innovation, competitiveness and job creation” through an “open exchange of information” that includes “affected stakeholders” – exactly the opposite of what is happening today in the HUD program.
Consequently, after carefully examining the Order overnight, MHARR, on January 19, 2011, acted to press HUD officials to fully comply with this Order as it relates to all aspects of the federal manufactured housing program including, most importantly, its ongoing rapid expansion of in-plant regulation. This expansion, which began innocuously as a program of “voluntary cooperation,” is now being transformed into a full-blown de facto regulation that will needlessly increase regulatory compliance costs passed to consumers by manufacturers and retailers, as the ongoing expansion now appears to target both. Details of the latest phase of this expansion, developed entirely behind closed doors, are emerging piece-by-piece, having been adopted without any official procedures.
All of this is addressed in detail in the attached copy of MHARR’s self-explanatory January 19, 2011 MHARR letter to HUD Assistant Secretary-Federal Housing Commissioner, David Stevens, a copy of which is attached for your information and review. This letter addresses the ways that the President’s January 18, 2011 Order applies to – and must alter – the practices of both the HUD regulatory program and HUD’s consumer financing programs, specifically including the FHA Title I manufactured housing program, which has been subject to severe limitations which thwart competition and market growth.
We urge you to carefully review this package, as it provides details of the latest phase of HUD’s ongoing expansion of regulation – mandatory three-day audits and costly enhanced Subpart I involvement by third-party inspectors – that are on-course to be imposed on manufacturers and retailers, because the industry establishment in Washington, D.C. refused to join forces with MHARR in order to force HUD to comply with the law by going through consensus committee and rulemaking procedures. Now, as shown by the attached letter, the industry has a major task on its hands to try to stop this.
MHARR, therefore, in an effort to curb and reverse the course of this runaway expansion of in-plant regulation, will now include and use the President’s Order and its January 19, 2011 letter to HUD in its overall ongoing activities with the 112th Congress, to demonstrate how HUD is violating the Administration’s own policy.
We will continue to keep you apprised as new developments on these issues unfold.
Danny D. Ghorbani, President
Manufactured Housing Association for Regulatory Reform
1331 Pennsylvania Ave N.W., Suite 508
Washington, D.C. 20004
Back from its Summer recess, Congress has embarked on a process that will ultimately determine – as soon as 2011 – the future role of the federal government in private-sector housing finance and the future role, structure and character of the Government Sponsored Enterprises (GSEs).
On September 15, 2010 the House of Representatives Subcommittee on Capital Markets, Insurance and Government Sponsored Enterprises held a hearing on “The Future of Housing Finance – A Progress Report on the Government Sponsored Enterprises.” Although the “duty to serve underserved markets” (DTS) mandate imposed on the GSEs by the Housing and Economic Development Act of 2008 (HERA) was not addressed as part of this more broadly-focused hearing, both the implementation of the DTS mandate and the future availability of private consumer financing for manufactured homes will ultimately be at stake in this process. Moreover, the challenges that the industry faces in this process were underscored in testimony by both the Administration and the current federal regulator of the GSEs, the Federal Housing Finance Agency (FHFA), as well as in statements by Subcommittee members.
While the Administration has not yet offered a detailed plan for the future of the GSEs, and is not expected to do so until early 2011, Michael S. Barr, Treasury Department Assistant Secretary for Financial Institutions, reported on the steps taken by the Administration in response to the financial crisis as they relate to the GSE’s as well as the Administration “Objectives and Goals for Housing Finance Reform” – i.e., widely available mortgage credit, housing affordability, consumer protection and financial stability to achieve those goals. He then outlined several policies including the necessity for “clear mandates.” Specifically, institutions that have government support, charters or mandates should have clear goals and objectives. Affordable housing mandates and specific policy directives should be pursued directly and avoid commingling in general mandates, which are “susceptible to distortion.”
Follow-up questioning by the Subcommittee focused on who was responsible for letting the GSEs get out of control and what contributed to their collapse. Some Republican members alleged that the housing goals forced the GSEs to get involved in sub-prime lending and to acquire sub-prime mortgage backed securities. Democrats and Secretary Barr responded that the GSEs acquired sub-prime mortgage backed securities to increase profits and that the housing goals did little to impact the GSEs collapse.
Significantly, though, subsequent testimony by FHFA Acting Director Edward J. DeMarco, expressed reservations about the Administration’s strategy, stating:
“Recently there has been a growing call for some form of explicit federal insurance to be a part of the housing finance system of the future. The potential costs and risks associated with such a framework have not yet been fully explored.”
Without either explicitly endorsing or opposing such a role for the government, he stated three specific concerns in his testimony:
First, he rejected the premise that no private firm would risk funding a 30-year mortgage, “at least at any price that most would consider reasonable.” Rather, he asked “whether there is reason to believe that the government will do better?” noting that “if the government backstop is under-priced, taxpayers eventually may foot the bill again.”
Second, he stated that a government guarantee could allow politicians to favor some areas or demographic groups, noting the government “would likely want a say with regard to the allocation or pricing of mortgage credit for particular groups or geographic areas.”
Third, he stated that a guarantee would shift capital toward housing, which already benefits from other government support.
Discussion among Subcommittee members then addressed moving forward – with some Republican members favoring complete privatization and the elimination of all housing finance goals. Their view is that goals will distort the market and lending will be to higher risk or with less of a down payment.
Regardless of whether there is any such specific guarantee, however, and regardless of the ultimate nature of the GSEs or successor entities going forward, the original mission of GSEs – as embodied in and strengthened by the DTS mandate – to provide home ownership opportunities for lower and moderate-income Americans, was not responsible for the GSEs’ failure and must be maintained in order to ensure that home ownership remains available to as many Americans as possible.
Another hearing on the GSEs is slated to take place later this month. MHARR will continue to carefully monitor these hearings and take further steps relating to DTS and proper GSE support for manufactured housing consumer financing as appropriate.
MHARR will keep you apprised as new developments on this important matter unfolds.
With Congress in recess and with members back in their districts for the balance of the Summer, now is the best time of the year for industry members to seek out, communicate with – and meet – their federal representatives away from the distractions of Washington, D.C. While MHARR is in regular contact with Congress in Washington, D.C. in order to address and advance issues of importance to both the HUD Code industry and consumers of affordable housing, members of Congress are always anxious to hear directly from their constituents on matters that concern them. This is particularly true leading up to the November 2010 mid-term elections, with the control of Congress hanging in the balance.
As a result, grassroots industry members have an outstanding opportunity over the next few weeks to tell their members of Congress directly about the major challenges that the industry faces in Washington, D.C. in key areas, including private and public financing (i.e., the “Duty to Serve” and FHA Title I), and continuing issues affecting the HUD Title VI program, including the deteriorating status and stature of the Manufactured Housing Consensus Committee (MHCC) and the avoidance of – and non-compliance with – required consensus and rulemaking procedures by program regulators on major regulatory issues, such as the ongoing de facto expansion of in-plant regulation.
The common thread running through all of these issues (and many others), that needs to be constantly reinforced with Congress, is that the difficulties the industry faces in Washington, D.C. do not arise from the lack of good laws. To the contrary, Congress has provided the industry with highly beneficial legislation over the past decade, including the Manufactured Housing Improvement Act of 2000, and the “Duty to Serve” and FHA improvement provisions of the Housing and Economic Recovery Act of 2008. Instead, much of the difficulty faced by the industry is a consequence of the failure of relevant federal agencies to fully and properly implement these laws in a manner consistent with the intent of Congress. In large part, this occurs because of the comfort level that regulators routinely get from forces within the industry, or outside the industry, or both.
As many in the industry are rapidly recognizing, given the nature of the problem, the solution does not lie in passing more laws that will similarly be ignored or manipulated. Instead – and as MHARR has already begun to explore – ongoing industry engagement with Congress needs to be expanded to include effective congressional oversight of these matters to ensure that the good laws already on the books are respected and properly implemented by federal regulators. With the industry continuing to decline and with regulators’ continuing resistance to the full and proper implementation of these existing laws – which needlessly exclude consumers from the manufactured housing market – Congress needs to be fully engaged in an oversight capacity. And, the best time to embark on such an approach is right now, with one-on-one meetings of industry members with their congressional representatives, at home, in their districts, to be aggressively followed-up in Washington, D.C. by the industry’s national representatives.
Danny D. Ghorbani
Manufactured Housing Association for Regulatory Reform
1331 Pennsylvania Ave N.W., Suite 508
Washington, D.C. 20004
MHARR VIEWPOINT – AUGUST 2010
By Danny D. Ghorbani
The first step in solving a problem — any problem — is admitting to yourself that there is a problem, that the problem is real and that it exists. The second step, and perhaps the most difficult, is to accurately assess and define the problem, so that one or more potential solutions can be considered, weighed and, ultimately, implemented.
By any objective measure, the HUD Code manufactured housing industry has a problem. Over more than ten years, production and sales have plummeted. From a modern high of more than 373,000 homes in 1998, production in 2009 fell to below 50,000 homes. The trend in the statistics, moreover, has been steadily downward, and appears — over the long-term — to transcend both positive and negative changes in the broader economy and the broader housing market. No amount of happy talk or glad-handing can paper over this fundamental fact — the status quo for the industry and its consumers is unacceptable, and must be changed.
But that is the easy part. The more difficult part is defining the problem as an avenue to arriving at solution(s) that will work. To start, we can identify what is not a problem — and that is our relations, as an industry, with Congress and the lawmakers in Washington, D.C., who pass the laws that govern our comprehensive regulation by HUD and the finance programs and entities that impact the ability of lower and moderate-income Americans to purchase industry products that they can afford without costly subsidies.
The track record of the industry and its representation in Washington, D.C. within this realm is quite good, and the reason is very simple — manufactured housing and the manufactured housing industry are favored by legislators in Congress. And for good reason. The industry provides jobs that will stay here in America, without outsourcing. The jobs that the industry provides are well-paying manufacturing jobs, typically located in the heartland of the country, where the success or failure of the broader economy is largely determined. The industry, moreover, produces homes that provide affordable home-ownership for American families at all income levels without tax-funded subsidies. The industry, therefore, provides a vital resource — affordable home-ownership — without asking for tax dollars, only parity with other types of housing in various government housing programs, such as FHA programs.
So, Congress has been good to the industry. In 2000, it passed the Manufactured Housing Improvement Act, to take manufactured housing into the 21st century and complete its legal and policy transition to the legitimate housing. In 2008, aware of the trouble that consumers were having with financing, Congress included two critical manufactured housing provisions in the Housing and Economic Recovery Act of 2008 (HERA) — the “duty to serve underserved markets,” designed to expand and improve private financing and end discrimination against manufactured housing by the Government Sponsored Enterprises (GSEs), and FHA Title I and Title II improvements, designed to expand and improve public financing for manufactured homes financed as chattel, real estate and as part of land-home packages.
These are all good laws, designed to promote the availability and use of affordable manufactured homes. These laws should have fostered an industry boom in the solid national economy of the years following 2000 — with an industry expansion involving hundreds of thousands of homes — and should be helping to foster an industry revival now, in a post-recession economy. At least that was the hope — and the theory. But, things have gone wrong, and therein lies the problem.
The problem is that none of these good laws are being implemented in the way that Congress wanted, and expected. The 2000 reform law has been gutted by HUD regulators and attorneys. There is no — and has been — no appointed program Administrator for most of the past ten years. Enhanced preemption has never been implemented. The MHCC — the real centerpiece of the 2000 law — is being turned into another rubber-stamp “advisory council.” Its proceedings have been taken over by program regulators and a large chunk of its authority was taken away when HUD — without any public comment — read catchall section 604(b)(6) out of the law, which required HUD to bring enforcement policy and practice changes to the Committee.
HERA-based FHA Title I improvements have fared no better. Inexplicably delayed for years, those improvements are now finally being implemented, but their impact appears likely to be minimized by recently announced Ginnie Mae requirements for the securitization of new Title I loans ($10 million minimum adjusted net worth plus 10% of outstanding manufactured housing mortgage-backed securities) that will severely restrict access to the program by the new lenders that will be needed to appreciably increase the availability and number of manufactured housing loans for consumers.
Similarly, the proposed rule to implement DTS published on June 7, 2010, represents a major disconnect with the intent and objectives of Congress that, if implemented, will predictably fall well short in helping to end the discrimination against manufactured homes by the GSEs, that lies at the root of the current near-unavailability of manufactured home financing.
Despite good relations with Congress, then, and good laws passed for the benefit of the industry and its consumers, the results have not matched expectations. The implementation of each of these laws, by relevant federal agencies, has not come even close to what Congress wanted. And in certain respects, these agencies are openly defying clear congressional directives.
The pattern, therefore, is clear. Congress tries to help the industry and, then … nothing — or close to nothing or, sometimes, worse than nothing. For an industry that is comprehensively regulated by the federal government and, thus, thrives or declines based on decisions made in Washington, D.C., this is — and has been — a prescription for trouble. As an industry, we have an obligation, to ourselves and to our consumers, to question — to ask why this is happening, and how it can be fixed before much of the industry falls by the wayside, leaving only a handful of survivors. MHARR is asked constantly why the industry is so impotent in Washington, D.C. in the face of continual resistance by regulators and other administrative types to the proper implementation of the good laws that Congress provides us. MHARR , in response, has studied this issue, going back over the history of the industry’s presence and involvement in Washington, D.C., dating back to the start of federal regulation, to find workable solutions, and will share its findings and suggestions in the September 2010 MHARR Viewpoint.
In MHARR’s view, the industry’s inability to implement critical laws despite strong Congressional support lies at the core of the industry’s difficulties, and needs to be addressed decisively.
MHARR is a Washington D.C.-based national trade association representing the views and interests of federally-regulated manufactured housing.
Thanks for sharing the below announcement…and you are correct, as we, too, have noticed lately that the rest of the industry is coming closer to the MHARR’s well-established priorities in the Nation’s Capital (i.e., full and proper implementation of the industry’s three existing reform laws, namely, the FHA — public consumer financing — and the Duty to Serve — private consumer financing –segments of the 2008 HERA law, as well as the 2000 reform law) for halting and reversing the ongoing decline of the industry…and MHARR wholeheartedly welcomes this development.
And, too, the announcement is correct about the Congress’ recognition of our industry…..in the 2000 Reform Law. This “recognition”, however, will be fully achieved when all reform provisions of the 2000 law are fully and properly implemented, which, as MHARR has documented in greater details time and again, has not been the case since the inception of the law in 2000. Thus, it is a bit disappointing that the full and proper implementation of the 2000 Law (which would fully and comprehensively transform our industry from trailer to housing) is not part and parcel of the announced priorities. Furthermore, it is noteworthy that as important as “standards updates” and “protection of preemption” are to both the federal program and the industry, they are but merely two of a myriad of interconnected and interactive reform provisions of the 2000 Law, which have not been fully and properly implemented after ten years.
All that said, this is a welcomed step by the rest of the industry, and MHARR looks forward to assist, foster and advance industry consensus views, and corresponding positions, on these important matters in the Nation’s Capital.
Thank you again…and, hopefully, you wouldn’t mind my sharing this with our members.
cc: MHARR Members
Danny D. Ghorbani
Manufactured Housing Association for Regulatory Reform
1331 Pennsylvania Ave. N.W. Suite 508
Washington, D.C. 20004