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Posts Tagged ‘Dodd-Frank’

An Important Contribution to Understanding Manufactured Housing Finance

May 19th, 2015 No comments

Tony,
This special report is very effective in explaining the complex topic of chattel financing and the negative impacts of Dodd-Frank.  Using a real life story, and the final, more costly financial option that the consumer had to turn to shows the devastating irony of Dodd-Frank’s causing more harm than good to the goal of affordable housing.

Congratulations on this important contribution to the understanding of the MH financial world.

Joe

Dodd-Frank and Manufactured Home Financing: The Place Where Good Intentions and Unintended Consequences Collide

joe-kelley-iowa-manufactured-housing-association-industry-voices-mhpronews-com-1Joe Kelly

Iowa Manufactured Housing Association

(Editor’s Note: a number of MH Pros have praised award winning journalist Jan Hollingsworth work in the story above. Associations and corporate leaders are among those who have sent or called kudos for her story).

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.)

Kudos for Ron D’Ambra’s thoughtful article on the HUD Code and Manufactured Housing Affordability

September 5th, 2014 No comments

As a former manager of the HUD Manufactured Housing Program, I was gratified to read Ron D'Ambra’s recent piece titled “Are HUD Practices Making Manufactured Homes Less Affordable?”   While there are always some costs associated with any form of government regulation, Ron clearly appreciates the long term benefits that HUD has brought to an industry that was previously known for building low quality firetraps. 

Though a small clan within the industry reflexively condemns just about everything HUD has done over the years, I’d recommend Ron’s review of HUD’s history and various functions to anyone who wants to understand the enormous strides in quality and safety the industry has made since HUD first set up its program shop back in 1976.

Rather than repeat Ron’s points, let me add one of my own.

When the Act was passed in 1974, its title referred to the products as “Mobile Homes” and the language of the Act often referred to the products as “vehicles”. It has always seemed to me that Congress was thinking of the industry’s products as more like automobiles than houses for regulatory purposes.Thus the “Notification and correction of defects by manufacturer” requirements in 42 U.S.C. 5414 which are implemented in Subpart I of HUD’s regulations.

Compliance with these requirements represents most of the real HUD compliance burden, which requires remedies much like automobile recalls for the life of the home.

Given that the quality and safety of manufactured homes now equals or exceeds that of site built homes in most respects, perhaps the time has come to ask Congress to reconsider replacing the current requirements of 42 U.S.C. 5414 with some sort of warranty.For all I know, this idea has already been discussed, but I left HUD in 2010 and may have missed it.

Anyway, on behalf of the hundreds of people who have staffed the HUD program, served as HUD IPIAs and DAPIAs, as HUD contractors and Consensus Committee Members, thanks very much Ron for your thoughtful piece.##

bill-matchneer-formerly-with-hud-and-cfpb-posted-industry-voices-mhpronews-com-aBill Matchneer, JD, recently retired from 23 years of federal government service. Most recently he supervised the Dodd-Frank appraisal rules at CFPB, but is better known to our readers for his ten years as manager of the manufactured housing construction and safety standards program at HUD. Bill can be reached at (703) 973-4366 and at bill.matchneer@comcast.net

(Editor's Notes: A recent interview with Bill Matchneer is found linked here.

As a matter of MHProNews policy, we routinely encourage a variety of viewpoints, which may or may not reflect those of the publisher or our sponsors. You can submit a Letter to the Editor or OpEd to: latonyk@gmail.com or tony@mhmsm.com).

The Value of IMAGE, The Image of VALUE

July 9th, 2014 No comments

There is much talk of the need to “do something” about our industry’s image. Wow, that’s some understatement!

But what? And how? And who will pay for the refurbishment?

It’s a deep problem. It’s hard to refurbish an image that was never really “furbished” in the first place! The MH industry has a lot of growing up to do, and it’s quite a challenge.

Tony Kovach recently published the following graph.

manufactured-housing-mobile-home-shipments-graph-chart-calculatedrisk-posted-masthead-blog-mhpronews-com-

Our eyes jump to the trend of the past decade, which emphasizes the need to “do something.” I invite you to study the other end of that graph. The sixties.

In that decade, as today, the rule of thumb for a stick builder was to dedicate about half of construction cost to materials. That didn’t work for those building homes in factories. They had to build a product sturdy enough to ship a thousand miles on its own wheels, and if material content dropped below 60 percent—lock the factory doors. No reputable dealer would buy. In those days, despite buying all that material factory-direct and very efficient labor, the MH cost was far higher per square foot than a house (excluding land).

By the end of that decade, the rule of thumb—the MH optimum for sales maximization—was 70 percent material, 10 percent labor, 10 percent overhead and 10 percent pretax profit. In good years, that worked and profits rolled in. In bad years, you got hammered.

Sounds like a loser business?

Not if you knew your stuff. If you managed 30-plus inventory turns, collected cash on delivery of the homes, operated in a pole-barn factory and had nominal investment, you could operate on your supplier’s 30-days-same-as cash payment plan. Banks released floor-plan cash upon delivery of the home. 100 percent return on equity was not out of the question. But everything had to work.

Look again at Tony’s graph. Everything did work during that decade for those who managed well. A year of no sales increase was considered a recession.

Manufacturers had to master that formula or get out of the race. Competition was brutal, but everyone understood that no one could do it alone. Manufacturers, suppliers, dealers, developers and banks. All were highly profitable when they got their sums and strategies right.

The quality of manufactured homes soared and the cost of producing them plunged. Such was the magnitude of opportunity in the sleepy housing industry.

It was Skyline, Fleetwood and the like who got the publicity—biggest MH manufacturers, most profitable companies in the stock market and all that. Surely they should have stepped up to the plate and “done something” about the industry’s image?

Well, they did what they could, but their hands were tied. Every nickel of such a manufacturer’s profit would have funded just one percent of industry sales for an image-building program. And what, one might ask, could a manufacturer have done for its image more useful than investing in product improvement? That’s what the critics and customers requested, and rightly so.

The largest manufacturers each held less than 10 percent market share and had plenty of competition snapping at their britches. Which of those “leaders” should have stepped up to the plate and invested significant funds in the industry’s image? Sure the profits were good, but they didn’t stay that way.

Look again at Tony’s graph, and what happened when things stopped going well for the industry in the early seventies. That’s why there was so much resistance to the HUD standard, and still is. That’s why it has always been hard to get those “big manufacturers” to spend “just a little bit more” on the want-of-the-week. If the competition doesn’t do the same, you’re toast. Real competition is not for the faint of heart, but it works wonders for customers.

Competitive product improvement, step by step. Learning curve. That’s how the MH industry cut the cost of building homes in half. Focused, efficient, production in a housing market where nobody was in charge, regulation was rampant and good times were rolling. Don’t hold your breath waiting for a repeat of that kind of housing opportunity.

My enthusiasm for today’s outlook is based on the fact that the leaders have survived and now have commanding market share, while retaining—improving—their production cost advantage over the stick guys. I don’t know what the Big Three’s margins are, but they’re profitable. We’re in a new and potentially better ball game.

The outlook is marred by the yo yo of housing demand, fluctuating with the whims of the economy and regulators. That’s why, when asked to write a book on the potential of manufactured housing, I said, “You’ve got to be kidding!”

It didn’t take much research to change my mind. The survivors seem to have learned to cope with such market volatility and stifling regulation. The production cost advantage is still increasing and the competition continues to doze. Well managed surviving MH producers remain profitable in a scenario that would have crushed any normal manufacturing industry long ago … but woe to the manufacturer who single-handedly takes on the cost of a major industry image upgrade.

It needs to be done, but has to be a team effort, with participation by most members of the industry at large. And there has to be strong leadership so we all head the same direction.

Given the squabbling we all see and regret, is there any hope?

Of course there is! The MH industry has always been a teamwork affair, where even bitter enemies worked together to keep the system functioning, because we all had a vested interest in keeping this marvelous housing system pumping, cranking out houses and profits. That has not changed.

Sure HUD, Dodd-Frank and their ilk are a royal pain in the butt, but they strangle the other guys, too. Despite best efforts of bureaucrats to rule by regulation, economics will win in the end, and we’ve figured out an inherently better way to build houses.

Yes, for a time we fouled our nest. Young industries do that. Yes, the public disdains “trailers.” Tell me what sort of low cost housing they like? Nobody wants low cost housing except those having a nose for value or low income. Those are huge markets that no other product can satisfy that need as well as manufactured housing.

What we lack in image, we more than make up in value.

Let’s build on that. ##

bob-vahsholtz-author-dueling-curves-battle-for-housing-posted-industry-voices-guest-blog-mhpronews-com-manufatured-housing-professional-news-75x75-Bob Vasholtz is the author of Dueling Curves. Bob Vahsholtz is the author of DUELING CURVES The Battle for Housing. Bob can be reached at kingmidgetswest@gmail.com. Web: www.kingmidgetswest.com

A prior guest column from Bob – Who's in Charge Here – is linked.

 

(Editor's Note: The chart show above is courtesy of CalculatedRisk and was used in the following article, Manufactured Housing's Declaration of Independence. As with all letters to th editor, articles and guest column, the views represented are those of the writer. Other perspectives are welcome, email latonyk@gmail.com with Letters to the Editor or OpEd in the subject line.)

Financing in the CFPB Era and the Path to Full Manufactured Home Communities

June 24th, 2014 No comments

Tony,

Great articles and comments made by others. 

I agree with 99% of what is said. The issues I see our industry has are: 

  1. People are so scared of the Dodd-Frank and Safe Act. Our industry needs to deal with this as the new reality and figuring out how to do business with these new regulations. 
  2. Lenders and community owners getting together on a win-win community home financing program that requires community owners to repurchase the homes that default and requires the lenders to originate loans at lower rates. 
  3. Community owners making their communities more appealing to today’s buyer:
    1. Updating their community amenities (Signage, clubhouse paint and carpet, pool furniture, road repairs, etc.)
    2. Enforcing communities rules to ensure that all homes are maintained and clean and neat
    3. Finding ways to improve the community lifestyle by organizing community events that enrich the residents lives.
    4. Moving in new homes and having 2 or more fully decorated models that will help prospects visualize how nice a manufactured home can be.
  4. Community owners should NOT jump into the rental home model so fast. Many markets can support true home sales business model by offering financing options that make sense to their customers. This does take more work but the full community with home OWNERS rather then renters is worth the extra work. 
  5. Community owners offering outside retailers attractive move in programs. 

We have implemented this in all our communities and are selling anywhere from 30-100 homes per community per year. 

Thanks for sharing this article. ##

scott-roberts-roberts-resorts-posted-industry-voices-guest-blog-mhpronews-com-Scott Roberts
Chief Executive Officer
Roberts Resorts
8350 E. Raintree DR. Ste 220
Scottsdale, AZ 85260
480.425.8696

scott-roberts-roberts-resorts-posted-industry-voices-guest-blog-mhpronews-com-(Editor's Note: The articles Scott's letter to the editor refers to are ones by Ross Kinzler and Jay Hamilton.

For those who may not have met Scott or know the progressive work being done in his communities, Scott was the recipient of the Manufactured Housing Institute's “Community of the Year” at the 2014 Congress and Expo.

The head shot above is actually part of a larger photo, that shows him holding his Community of the Year award.)

Manufactured Home Factory Tour with my Congressman

June 5th, 2014 No comments

Back in February when I visited with Congressman Bill Flores in Washington, I asked him if he had ever toured a manufactured housing plant.A couple of months ago, one of his staffers contacted me wanting information about the manufacturing facilities in Waco.I had replied with information about Fleetwood Waco and about Clayton Homes two facilities in Waco.I gave him information on the Clayton and Fleetwood facilities, explaining that while as TMHA Chairman I represented the entire state, my retail location had carried Fleetwood product for some years, but that I was sure either company would be more than willing to provide a tour.

Last Wednesday, I received an email from his scheduler, Jessica Harrison for contacting me about Representative Flores coming to visit Fleetwood Homes manufacturing facility in Waco.

Texas Manufactured Housing Association (TMHA) Director D.J. Pendleton, myself, and Gay Westbrook of the MHI, made the trip as well as Don McCann, the manager of the Clayton Homes Waco manufacturing facilities.We were joined there by Ray Parma and Zach Sanders, the GM and Sales Manager respectively of Fleetwood Waco. 

I can report to everyone that the visit and tour went outstandingly well.

Rep. Flores was very engaging of plant manager Ray Parma; the congressman asked questions during the plant tour about everything from frame camber, to shear wall design and how it impacted tie-downs.  I could just see Ray’s eyes gleaming with getting to share his many years of experience at the plant. It was a pleasure to all of us in attendance that the congressman genuinely cared about what went into our products and the people who made them.Zach had the opportunity to visit with his District Director during the tour and field questions from him as well.

fleetwood-plant-tour 6-2-2014-for-congressional-representative-flores-550x512-.png

While we can all brag about our differing product lines at shows and conventions, Ray and Don gave a great one-two punch by providing Rep. Flores with fact that between their facilities in Waco alone, there were over 750 constituent employees in his district and at least that many more in vendors that provide material for those facilities.

Rep. Flores met with all of us after the plant tour and discussed not only Dodd-Frank legislation and the CFPB, but also things that affect manufacturing facilities such as OSHA inspections and health care for employees.  It was good to see friendly competitors coming together to express concerns to the congressman. 

All in all, it was a great visit.

My sincerest thanks to all who took time out of their schedules to be a part of the event and thanks to past MHI Chairman and current Cavco CEO and Chairman, Joe Stegmayer, for allowing the use of the Waco facility for the tour. ##

karl-radde-texas-manufactured-housing-association-chairman-mhi-retailer-division-vice-chairman-posted-industry-voices-manufactured-housing-pro-news-mhpronews-comKarl Radde, GM
Southern Comfort Homes
Chair of TMHA and Vice-Chair of MHI National Retailer’s Council
karl@schomestx.com

Who’s in Charge Here?

June 3rd, 2014 No comments

Rick Rand’s excellent proposal for an all-industry conclave at a neutral location is gathering momentum. Such a venue should certainly not screen out the smaller operators who have always been a prime source of innovation, and it is vitally important that the “big guys” also be at the table. Make room for the various associations charged with the thankless task of placating the placating the industry’s many voices.

As a long-retired veteran of manufactured housing, I’m appalled at the conflicts, back-biting and lack of leadership that has always hamstrung our young industry. It was understandable in the early days when the largest manufacturers controlled less than ten percent of shipments and no other industry constituent was in a position make things happen beyond his own company (in those days, the leading players were all men).

Today, though manufactured housing is a shadow of its former self, the product itself is far better, the need for affordable housing is far greater, the leading manufacturers remain profitable, the market for manufactured housing communities is heating up and the stick competition is in disarray. So why are our sales volumes in the dumper?

It is true of course that we, as an industry, have made many mistakes. And we’ll make more.

In a free enterprise system, we learn from our mistakes and keep moving forward. That’s exactly what needs to happen at the kind of meeting Rick has proposed. Pull the tribe together with an agenda focused on the problems we’ve created, the opportunities ahead and agree upon a broad based strategy to deal with today’s challenges. Ideas and innovations are often sparked over a cup of coffee or glass of beer, and contacts have always been the lifeblood of the industry.

But far more is needed than griping about Dodd-Frank and what names we should use for our products. Consider some fundamentals.

Housing is one of America’s least efficient industries. That includes stick builders and us too. Why is that? Well, there’s no serious foreign or domestic competition, no real industry leadership, way too much regulation and negligible innovation. That’s been the case for a hundred years.

Academics and all sorts of advanced thinkers have, for at least that long, looked to industrializing the building process to break out of housing’s quagmire. It has finally happened. The industry we now call manufactured housing has demonstrated the ability to build good housing at roughly half the cost of traditional methods, and we have the black eyes to prove it.

As one result, America’s largest home builder is one of us, and one of the world’s richest men bankrolls MH financing. Something like 20 million Americans live in homes we’ve built and the vast majority of them appreciate the comfort and value those homes provide. There’s ever so much more that could and should be done, but we’ve made a better start than any other tilter at housing’s windmills. Many have tried.

One thing the MH industry agreed upon some 40 years ago was to unite under the HUD banner. That turned out to be a painful process with about as many negative as positive outcomes. We banded together again to reform that process with the Manufactured Housing Improvement Act of 2000 (MHIA 2000), but guess what? Big Brother has its own ideas about “Improvement” which do not include a lot of use for industry committee input.

We’ve got a lot going for us, and yet the squabbles continue. If there’s an industry strategy, it did not emerge from my recent research. What is happening is a plethora of tactics, put forward under various banners, mostly going nowhere.

As an industry professional, you can put forward some ideas for how to deal with these challenges. So can I, and I’ve done so in my recent book, Dueling Curves. It’s not enough.

Maybe at Rick’s gathering of the tribes, some sort of consensus can be reached, on a whole bunch of nifty ideas.

But that’s not enough either.

The single most important objective of such a congress—or whatever it’s to be called—should be to the emergence of industry leadership. Not a task force, committee or agency, but a person of vision who commands the respect of the industry.

A tribal chief who can weave the disparate strengths of the manufacturers, suppliers, financiers, retailers, MH owners and community operators into a strategy we can all salute. Oh well, yes, there will always be a few curmudgeons. No one will be entirely happy with any strategic vision adequate to unite us; not even the leader who ultimately propounds it.

But let me suggest this. Should we fail to unite behind competent leadership, I can suggest who will become take charge of the industry. Well, maybe I shouldn’t name names, but the initials are H.U.D. ##

bob-vahsholtz-author-dueling-curves-battle-for-housing-posted-industry-voices-guest-blog-mhpronews-com-manufatured-housing-professional-news-75x75-Bob Vahsholtz is the author of DUELING CURVES The Battle for Housing Bob can be reached at kingmidgetswest@gmail.com. Web: www.kingmidgetswest.com

The RV Industry is Attempting to Amend the HUD Manufactured Housing Code

May 28th, 2014 No comments

The Recreational Vehicle Industry Association (RVIA) is pushing a proposal through the U.S. Congress to change the definition of manufactured home in the National Manufactured Home Construction and Safety Standards Act.  The proposed change would specifically exclude certain “RV trailers,” including Park Model RVs, from the definition of a manufactured home in the federal HUD Code.

The stated purpose of the proposed change is to provide regulatory certainty to lenders, state or local taxation and land use officials that a Park Model RV is a recreational vehicle, not a manufactured home.

Their urgency for this change is that some lenders are apprehensive about making Park Model RV loans in light of the new Dodd-Frank Act requirements.

A concern with the language, as proposed, is that it may allow ANSI Park Model RVs to expand beyond the current 400 square foot size limitation. 

This would be harmful to the HUD-Code RV Park Model industry in states like Florida by encouraging the sale of ANSI Park Models that exceed 400 square feet.

The proposed amendment states, “a park model RV that has a gross area not greater than 400 square feet based on the exterior dimensions of the unit measured at the largest horizontal projections in the set-up mode, including all floor space that has a ceiling height of more than 5 feet” (emphasis added). 

The ceiling height language was inserted to codify a 1997 HUD interpretation that loft areas which are less than 5’0” in height are not considered in determining the size of the structure. The proposed language does not limit the ceiling height exclusion to loft areas, thus allowing for the possibility of “slide-out rooms” or “build-outs” less than 5 feet high.

RVIA is emphatic that the intent is not to increase the size of ANSI Park Model RVs.

According to RVIA, concerns about enlarging the size of Park Model RVs are unfounded because specific rules are in place to measure the size and calculate the square footage of Park Model RVs. Additionally, Park Model RVs are built to standards administered by the American National Standards Institute (ANSI), a national voluntary consensus body. The ANSI A119.5 standards would have to be amended to allow for larger structures.

While these safeguards are in place today, the statute will drive future requirements. If the federal law is ambiguous enough to assert that larger ANSI RV Park Models are allowed, then the rules will change to accommodate this view. 

The RVIA is working hard to get this amendment accomplished during the 2015 HUD appropriations process. RVIA is not looking for industry support, but rather seeks to quell any opposition.

MHI has taken a neutral position on the proposal, while MHARR is adamantly opposed to it.

This proposed change to the National Manufactured Home Construction and Safety Standards Act will have a negative impact on the HUD-Code Park Model industry in Florida. Most Park Models are permanently sited and larger ANSI Park Model RVs will encourage permanent, year round living. ANSI Park Model RVs are designed and intended for recreational use and seasonal living only and are not built to the more stringent HUD building code.

The Florida Manufactured Housing Association (FMHA) has asked RVIA to consider amending its proposal to specify that the 5 foot ceiling height exemption applies to loft areas only. This will ensure that ANSI Park Model RVs are not built in excess of 400 square feet.

Reasserting the current size restriction in the proposed amendment will satisfy the RV industry’s objective of clarifying the differences between ANSI Park Model RVs and HUD manufactured homes for financing and land use purposes, while promoting ANSI Park Model RVs as a desirable option for recreational and seasonal accommodations. ##

james-ayotte-Florida-Manufactured-Housing-Association-posted-on-mhpronewsJames R. Ayotte, CAE
Executive Director
Florida Manufactured Housing Association
3606 Maclay Blvd. South – Suite 200
Tallahassee, FL 32312
Ph:(850) 907-9111
F:850) 907-9119
jayotte@fmha.org
www.fmha.org

ObamaCare and Manufactured Housing, Take Two

December 19th, 2013 No comments

In Obamacare, a Different Perspective, a well meaning Texas retailer advances his speculation that through the wonder that is Obamacare, fewer of our housing prospects will be forced into medical bankruptcy and a typical manufactured home retailer or stick built homebuilder might enjoy an increase of five or six sales per year. I believe our Texas retailer is well meaning with his speculation but several factors are not included in observation.

First: Having Obamacare does not mean you will be free from a risk of medical bankruptcy. Given the higher premiums being forced onto unwilling buyers along with massive deductibles, the risk of bankruptcy has in all likelihood been increased. Although we encounter very few medial bankruptcies, most of the ones I have encountered are able to find a path to home ownership because the medical burdens of the past are behind them. Under Obamacare the misleading information that premiums would drop has proven to be one more burden on the current administration as it proves to be untrue.

Second: Employers have laid off workers, decided to cancel expansion plans that would have required new workers and cut back the hours of existing workers due to the regulatory burden of complying with Obamacare. I have lost far more sales in 2013 due to these factors than a hypothetical increase in sales might have brought about had Obamacare been in place at the first of the year. We can get the bankrupt prospect past that event in their life and onto a path to homeownership. I can’t say the same for a client whose hours have been significantly reduced to the point of not budgeting for a reasonable house payment or a client who has lost their job.

Third: This same client will now be forced to purchase a federally mandated level of coverage which is an even greater drain on his discretionary income. Lower discretionary income means a lower likelihood of qualifying for the loan.

Fewer jobs, lower income, part time jobs, higher outgo, lower discretionary income will most likely not add up to an increase in business for the housing sector whether it be site built or factory built. Off topic, but to this mix you can add the new Qualifying Mortgage and other Dodd-Frank rules that will further erode sales. We need to dig in and adapt the best we can to all the changing rules that are headed our way. I respectively suggest that Obamacare will not be a boon to sales as was suggested.

doug-gorman.jpgRespectively,
Doug Gorman
Home Mart
Tulsa, OK

You Might Be a Redneck!

December 12th, 2013 No comments

You might be a redneck if: It never occurred to you to
be offended by the phrase, 'One nation, under God..'

You might be a redneck if: You've never protested about seeing
the 10 Commandments posted in public places.

You might be a redneck if: You still say ' Christmas'
instead of 'Winter Festival.'

You might be a redneck if: You bow your head when
someone prays.

You might be a redneck if: You stand and place your
hand over your heart when they play the National Anthem

You might be a redneck if: You treat our armed forces
veterans with great respect, and always have.

You might be a redneck if: You've never burned an
American flag, nor intend to.

You might be a redneck if: You know what you believe
and you aren't afraid to say so, no matter who is listening.

You might be a redneck if: You respect your elders and
raised your kids to do the same.

You might be a redneck if: You'd give your last dollar to
a friend.

You might be a redneck if you are tired of government overreach, such as ObamaCare, Dodd-Frank, the SAFE Act, CFPB and an alphabet soup of federal agencies that want to throttle our businesses or run our personal lives.

You might be a redneck if you've read this far, and you've nodded in agreement more than half the time. When I read some of the above from an article that had no author's name, and I added the last ones which impact manufactured housing home owners, professionals and the rest of our country too.

God Bless America! ##
Submitted by Larry Hahn