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9 Reasons Why You Need CRM

January 15th, 2014 No comments

Customer Relationship Management (CRM) is nothing new; it’s been around since the days of the Rolodex. Tickler files, ledgers, manifests, and even the ‘little black book‘ are relationship management tools that date back for centuries. But CRM has never been more important to closing sales than it is today.

Unless you do business on a very low scale (or work for only one or two clients) you are wasting precious time and missing sales opportunities if you’re not putting a CRM system to work for you. Here are 9 reasons why you need an effective CRM in your business:

Speed

Face it – the bulk of your leads and new customers likely come from online advertising – your website, directories, etc. If your customers find you on the web, they expect you to do business at the speed of the web, i.e., instantaneously. An effective CRM system should capture leads from online sources and send a response to new inquiries instantly and automatically.

The Fallibility of Memory

“The weakest ink is better than the strongest memory,” so the saying goes. And it’s true. Today’s sales professional is just too busy – and the workplace too hectic – to rely on memory alone to follow up with potential buyers. Without a single, organized place to record all client data, you will end up missing important communications – and losing sales. If you’ve ever grabbed whatever piece of paper is handy to record notes from an incoming phone call (and then lost or thrown away that paper as trash), then you know why you need a better system.

Awareness

Once you’ve attracted and recorded a new lead, you need a means to nurture their interest and remain front of mind with them. An effective CRM system will prompt you to keep in touch with prospects with relevant communications that address their key interests. Really good CRM systems will allow you to automate much of this process, including emails, phone calls, letters or post cards, and appointments. The goal: encourage a face to face meeting in your sales center.

Response

Nothing says “your not important; I don’t care” like failing to respond to a prospect’s question. Or not following up with them in a personal way. Or forgetting their name or the model or lot they’re interest in. An effective CRM system keeps all that information handy and accessible by computer, tablet or smart phone, and alerts you when you to appointments, incoming emails, or when it’s time to follow up with a phone call. And really good CRM systems allow you to store all relevant files – letters, plans, photos, etc., in the same place, so you always have every piece of information you need at your fingertips.

Management

So far, we’ve given valid reasons why every salesperson should use a CRM system. But it doesn’t stop there. If you manage a sales team, you need to know what opportunities are in the pipeline, which prospects are the most likely to close quickly, and what you can do to help move those urgent sales forward. You also need to see that every prospect is being properly followed up with by the sales consultant, and to give additional training and help where it’s needed. An effective CRM allows you to accomplish all that, and more.

Reports and Projections

What are your most effective lead sources and ROI from advertising? What are your projected sales (units and/or dollar volume) for the next month, quarter, and year? What is the average closing rate for your sales team? For individual salespeople? What is your average closing time, from initial contact to close? An effective CRM answers those questions and allows you to better manage your sales team, your advertising and your cash flow.

Service

Because your CRM program allows you to schedule appointments, tasks and alerts, you’ll be able to keep up with service calls or punch lists quickly, without ever worrying that an important call with fall through the cracks. Do you do annual maintenance, reviews, maintenance or renewals? Schedule these in your CRM, with alerts 30-days prior to the scheduled date to send notifications to customers and/or service agents. A really good CRM will automate these notifications and communications so you won’t have to.

Referrals

It should be the goal of every sales group to increase referral sales. A good goal is 30% – 40% of total sales. How do you reach that? By keeping in touch, servicing and nurturing existing customers or tenants. Every effective Customer Loyalty or retention program is powered by a CRM system. A CRM program will allow you to include past customers in any marketing events, such as open houses, seminars, or home shows, as well as send cards or congratulations on move-in anniversaries, for holidays, etc. A really good CRM will allow you to automate all of these processes, including alerts and email notifications, so that everything takes place seamlessly and without staff time to schedule.

Connectivity

While stand-alone CRM systems can provide all of the above, many will also connect and share data with other programs, such as your accounting program, inbound lead sources, rent or tenant management system, or point of sale program. This connectivity expands the value of a CRM to keep all customer data, from lead source to rent history, all in one place, saving time and avoiding ‘multi-system chaos’ that stifles use and frustrates business owners/managers.

So, there you have 9 good reasons to stop using that old, outdated spreadsheet or restrictive paper system and step up to a CRM system that will save you time, streamline your sales and marketing processes, and make your team more effective in closing more new and referral sales.

You should check out additional reasons to consider CRM at this story by Jason Brady linked below:

Start the Year off Right!

l-a-tony-kovach-scott-stroud-jason-brady-mhpronews-com1.jpg

Want to learn more? Then, join discussion moderator L. A. “Tony” Kovach, Jason Brady from ManufacturedHomes.com and me at the Louisville Manufactured Housing Show on Wednesday, January 23 at 9:30am SHARP for a special panel presentation on CRM for the Housing Industry. Go to this link at the www.TheLouisvilleShow.com site for details. ##

scott-stroud-posted-mhpronews-com-industry-voices-.jpgScott Stroud
180 Enchanted Dr.
Somerset, KY  42503
p. 606.677.04547

email:  sstroud@builderradio.com

(Editor's Note: The entire business building seminar lineup for the Louisville Show is linked here. It is currently the hottest page on their site, immediately after the home page!)

Rent Control in MHCs

September 4th, 2013 1 comment

Tony,

The phone rang one morning and a young man returned my call to him, we'd been playing phone tag. I had left a message with his wife in Oregon earlier, and he was calling about two Vermont MH communities I have listed for sale. From the voice of each, I guessed they were both far younger than I.

Speaking with him, as I answered his questions, it was obvious this was not his first call on LLCs for sale. In a knowledgeable way he wound thru the obvious questions, finally asking whether Vermont LLCs are rent controlled. Yes, I explained, they are. I went on to explain Vermont allows CPI, about 3% annually presently, without concern, and a big one, allows provable capital improvements in addition, annually. I told him that as a former VT LLC owner I had found the scheme fully workable, as do many of my contemporaries.

The next day I got an email message saying he and his partner/wife had decided not to invest in any locale where rent control is in force. OK, I get it, but that removes quite a swath of locales, many which are hot purchase markets. This philosophy allows investment in say Mississippi or Alabama, but negates purchases in Florida or much of California. Oh…

After that, my mind wondered over my experiences of the dangers of rent control and lack of it. Yes, I said the danger of the lack of it. I actually was pretty young once, had hundreds of apartments and almost 2000 MH/RV sites. With the exception of a Florida LLC, I was in no jurisdiction where rent control was in effect. And when rent control was threatened in a jurisdiction, I was the first to the battlements opposing its imposition. I was and am a capitalist, and rent control seemed an anathema to my beliefs. I'm not alone, right?

But time went by, slowly the days passed, and some of my beliefs at 40 years of age made transition to a more measured understanding as I aged and acquired experience I previously lacked. Let me be frank, I was an accomplished and notorious rent increaser, which in my twilight years brings me no acclaim by others, and more importantly, myself.

What I found was that in apartments, and we're not speaking of New York City here, the market rents in an area kinda act as rent control. You find yourself as the top dog in rent rate for your 1000 sq. ft three bedroom apartment in your area. What you are very likely to find, as I did, your apartment rents last and less, staying empty longer than it should. Recovering the lost time and money brings you back to Earth and unless your calqy is busted, your late debt payments slap Hai Karate hard. I found apartments very self correcting as to rents.

Now, on to LLCs. We all know the reasons we invest in communities; they own the dwelling unit, they can't move the house, etc. All good stuff, of course. So as I bought LLCs from original owner/developers, I found that as longtime owners they had allowed their rents to slip behind the market, keeping their management easy, with many long term residents.

Of course, the purchase price always reflected the oft unspoken premium of raising rents to market. "Hell, they can pay a lot more than that!" So I paid more than cash flow to get the community, not real unusual, right? Then the rent increases started. Often stiff and early increases happened shortly after closing.

The first few increases were swallowed, albeit with plenty of bitching by residents. We raised rents as much in two-three years as the former owner did in 10 years. Note that in some instances the increased rent still didn't pay for the capitalized investment costs. I knew that, they only knew and cared their rent had doubled in short order. No esoteric explanations of cap rates and other MH investor jargon seemed particularly persuasive to the LLC residents.

Who was it, Newton, who theorized every action has an equal and opposite reaction? I raised rents, they moved out. And I acquired a reputation in that community as a rapacious rent increaser. And these reputations are hard to escape. I wouldn't really care that much except the reputation had a very bad impact on homesite rentals. That, I did care about.

At first I did the calculation I see many others doing. Yah, I had 100 homes at $100 per month, and even though I'm quickly down to 90 homes at $111 per month, hey, I'm getting the same money with less work and expenses. And it keeps going this way as rents increase, residents fleeing like a torrent, out the MH Paradise Estates gates, which has turned into Hell Bent Acres.  And as vacancies mount, you lose control of the community, no longer able to count on the desire to live in your LLC to keep people in line. And that desire includes pricing.

Were I the only one to have followed the raise-rents protocols, then only I would have suffered the residue, but of course, such was not the case. The MH industry's then flawed model, subsidized for years by flawed lenders, finally collapsed, dropping from 373,000 shipments in 1998, then tantalizing us into believing the hurricane-inspired 135,000 shipments of the mid 2000s was the stopping point, to the grim reality of 50,000 homes in the 2010s. Yah, I hear 60,000 homes could happen any day now.

I sat in on some very contentious MHI committees in the late 2000s era trying to formulate a chattel long term lease the GSEs could swallow. In concert with this I reviewed many LLC profiles showing monthly rent and occupancy. It probably won't surprise you that the vacancy was truly scary, yet rents occurred steeply and frequently.  I had already tried that, and even with the generous retail financing by GreenTree, CIT, The Associates, Security Pacific, Chase and their ilk, it didn't work. Now we were dealing with the GSEs, who I did not find stupid, and we were trying to equate rents in LLCs to the capitalized valuation of single family conventional real estate lots. Any thought of sharply limiting rent increases to gain long term and low rate financing being the trade-off, got serious push back. Such was not to be and by then as the effort lost all bouyancy, the GSEs woke up to far bigger challenges.

As a post script I am the very first to admit that some major figures in that committee have since come far closer to the rent restraints advocated in the long term lease effort as their stated belief for industry resuscitation.  Will that be enough? I greatly doubt it, but I sure think it is an indisputable industry wide measure in the road back to something other than Warren Buffett's table scraps.

So to my young friend in Oregon, rent control, other then confiscatory NYC apartments or some California cities in MH, can be a useful LLC owner restraint, quieting some of the early animal spirits we can all exhibit before experience shackles us. Did I like going to the rent hearings in my community in Florida and taking phallus down the throat to the gag control center? Oh, I loved it.

Still, Florida LLCs are and have long been highly prized acquisitions, not greatly injured by the relatively manageable process for raising rents.  With the relatively benign rent control such as in Florida and Vermont, you and the industry are actually protected from many of the practices employed in the industry, leading to so much push back against us.

Before you believe I'm asking you to petition your jurisdiction for rent control, let me disabuse of that notion. Nothing could be further from the truth. I rail against governmental intrusion in to my affairs daily. Everyday the beast grows larger, only a financial collapse likely to abort its growth. The only point I am making is that one must practice rental increase restraint on your own. Sometimes laws can help a process.

The flip side is that lack of restraint causes lack of residents at a time LLC vacancy nationwide forebodes another step down in industry size. In places like Vermont and Florida and others, rent control, which one should practice on their own, is instilled by statute. Perhaps not the best solution, but the record says the world did not end there.

Yes, we tell a great story which seemingly has legs of truth about our affordable housing heritage. But for whatever reason, even though its great dog food, the dogs won't eat it. Perhaps a legacy of rapacious rent increases, closing parks, high default rates and high home value depreciation could be a good place to start the industry resurgence. We build great homes, but my friends, that, by itself is not enough. ##

marty-lavin-posted-on-mhpronews(MARTIN V. LAVIN
attorney, consultant & expert witness
350 Main Street Suite 100
BURLINGTON, VERMONT 05401-3413

802-660-8888 off / 802-238-7777 cell
marty@martylavin.com

(Editor's note: The hot link was added by us, not Marty, nor was the link requested in any way by Marty. We think it is good for others to realize that while Marty is 'retired,' he is still involved in this industry and clearly cares about manufactured housing deeply. That is why he sounds off on issues, because he cares enough to raise them for discussion, thought and action.

As always, letters and articles by you or your colleagues that may agree or take other perspectives are encouraged. Send them to latonyk@gmail.com with Industry Voices Guest Column in the subject line. )

MHARR Letter to HUD – Federal Housing Administration-Insurance for Manufactured Housing

March 29th, 2010 No comments

Manufactured Housing Association for Regulatory Reform
1331 Pennsylvania Avenue, NW, Suite 508
Washington, DC 20004
202-783-4087
Fax 202-783-4075

March 5,2010

VIA ELECTRONIC FILING

Regulations Division
Office of General Counsel
Department of Housing and Urban Development
45 1 Seventh Street, S.W.
Room 10276
Washington, D.C. 2041 0-0001

    Re: Docket Number FR-5075-N-02
    Federal Housing Administration-Insurance for Manufactured Housing
    Re-Opening of Public Comment Period

Dear Sir or Madam:

The following comments are submitted on behalf of the Manufactured Housing Association for Regulatory Reform (MHARR). MHARR is a national trade association representing the views and interests of producers of manufactured housing regulated by the Department of Housing and Urban Development (HUD) pursuant to the National Manufactured Housing Construction and Safety Standards Act of 1974, as amended, 42 U.S.C. 5401, et seq. (Act).

I. INTRODUCTION

On September 15, 2008, the Office of the Assistant Secretary for Housing – Federal Housing Commissioner published a proposed rule to amend HUD’s regulations governing manufactured homes that secure Federal Housing Administration (FHA) Title I loans and Title II insured mortgages. Under the proposed rule, portions of the current regulations, 24 C.F.R. 201.21 and 24 C.F.R. 203-43f, which require such homes to be installed in compliance with HUD’s “Permanent Foundation Guide for Manufactured Housing” (HUD Handbook 4930.3G), HUD’s “Minimum Property Standards for One and Two-Family Dwellings” and other related criteria, would be deleted and replaced with new sections that would allow FHA to insure most HUD Code manufactured homes installed in a manner that meets or exceeds the requirements set forth in the federal Model Installation Standard (MIS) adopted by HUD on October 19,2007 pursuant to the Manufactured Housing Improvement Act of 2000 (2000 reform law).

MHARR submitted comments (incorporated herein by reference) generally supporting this proposed rule — subject to concerns related to the non-preemptive status of the federal Model Installation Standard and corresponding federal installation program – on October 17, 2008. MHARR generally supported the proposed rule because, as HUD correctly notes, the “acceptance of mortgages on manufactured homes installed in accordance with the Model Installation Standards would provide for greater flexibility of design, thereby permitting additional options for affordable housing.”See,75 Federal Register, No. 23, February 4,2010, at 5706).

Subsequently, on February 4,2010, HUD re-opened comments on the September 15, 2008 proposed rule, because implementation of the federal manufactured home installation program (adopted by final rule dated June 20, 2008), including HUD certification of complying state-law manufactured home installation programs and provisions for HUD enforcement of the federal installation standards in states without state-law installation programs has been delayed. As stated by HUD in its February 4, 2010 Federal Register notice regarding re-opening of the comment period for the proposed rule:

    “… there have been some delays in submissions of state certifications, in HUDts review and acceptance of state certifications and in the implementation of HUD’s program for states in which HUD will administer the installation program. As a result, there are several states in which there is not yet either a state-certified and fully-accepted installation program or an operational HUD-administered installation program.”

(Id. at 5706-5707).

Because of this delay, HUD now seeks comment on whether it should: (1) promulgate a final rule based on the September 15, 2008 proposed rule, applicable in a given state only at such time that the state has either an operational state-certified and fully accepted installation program, or operational HUD-administered program, or (2) “delay promulgation of a final rule based on the September 15,2008 proposed rule until all states and territories have an operational state-certified and fully accepted installation program or a HUD-administered program.”

II. COMMENTS

MHARR opposes any further needless delay in the implementation of the proposed rule and, therefore, supports the first option proposed by HUD — the promulgation of a final rule based upon the September 15,2008 proposed rule that would become applicable in each state when the state has either an operational state-certified and fully-accepted state-law installation program, or an operational HUD-administered installation program.

The 2000 reform law, as one of the centerpiece reforms of the HUD manufactured housing program, directed HUD to adopt and implement federal installation standards and a corresponding federal installation program, by 2005, in each state that had not yet implemented state-law installation standards and a state installation enforcement program. Today, some ten years after the adoption of the 2000 reform law and five years after the deadline established by Congress for the full implementation of the fallback federal installation program in default states (i.e., states without a state-law installation program), that program, by HUD’s own acknowledgement, is still not fully operational. As a result, installation oversight, that would benefit consumers and help expand the availability of consumer financing (by enhancing the value of manufactured homes), is still absent in many areas. This delay, in turn, has become an obstacle to the full implementation of the September 15, 2008 proposed rule that would similarly benefit consumers by expanding their affordable housing options and the availability of muchneeded FHA financing.

Very simply, there is no excuse for this long — and continuing — delay in the full implementation of the federal installation program, a reform deemed so vital by Congress that it alone is subject to a specific statutory deadline set forth in the 2000 reform law. The full implementation of the federal installation program, however, like many other manufactured housing program reforms mandated by the 2000 law (as previously documented by MHARR), has fallen victim to continuing mismanagement of the HUD program — in the absence of the non-career manufactured housing program Administrator provided by the 2000 law — that has skewed program priorities and returned the program to the controversial, non-consensus practices that the 2000 reform law sought to change. For example, while the full implementation of the federal installation program has been delayed for years, HUD program regulators, for the past three years, have devoted limited program resources to the establishment of a “shadow” in-plant inspection system and procedure, wholly outside of existing regulations and without the consensus procedures required by the 2000 reform law.

In the interim, as the HUD program has resisted the reforms of the 2000 reform law, production and sales of manufactured homes have declined by nearly 90%, to their lowest level ever, representing a catastrophic loss of affordable housing opportunities for lower and moderate-income American families, as well as the loss of thousands of manufactured housing industry and related jobs across the United States.

As a result, it is essential that HUD reverse the deterioration of the manufactured housing program and move forward, as rapidly as possible, to fully implement all of the 2000 law reforms, including the fallback federal installation program and final certification of compliant state-law programs.

Consistent with this and for all the foregoing reasons, HUD should adopt, as soon as possible, a final rule based on the September 15, 2008 proposed rule that would become effective on a state-by-state basis upon certification of a compliant state-law program or the implementation of an operational HUD-administered program in accordance with option one as set forth in HUD’s February 4, 2010 Federal Register notice.

Sincerely,
Mark Weiss
Senior Vice President
Manufactured Housing Association for Regulatory Reform
1331 Pennsylvania Avenue, N. W.
Suite 508
Washington, D.C. 20004
(202) 783-4087 (Office)
(703) 509-9489 (Direct)
(202) 783-4075 (Fax)
mmarkweiss@aol.com (Email)
cc: Mr. Danny Ghorbani, MHARR

MHARR Letter to FHFA – Enterprise Affordable Housing Goals

March 29th, 2010 No comments

Manufactured Housing Association for Regulatory Reform
1331 Pennsylvania Avenue, NW, Suite 508
Washington, DC 20004
202-783-4087
Fax 202-783-4075

March 18,2010

VIA ELECTRONIC FILING

Alfred M. Pollard, Esq.
General Counsel
Attn. Cornrnents/RIN 2590-AA26
Federal Housing Finance Agency
Fourth Floor
1700 G Street, N.W.
Washington, D.C. 20552

Re: RIN 2590-AA26
2010-2011 Enterprise Affordable Housing Goals

Dear Mr. Pollard:

The following comments are submitted on behalf of the Manufactured Housing Association for Regulatory Reform (MHARR). MHARR is a national trade association representing the views and interests of producers of manufactured housing regulated by the Department of Housing and Urban Development (HUD) pursuant to the National Manufactured Housing Construction and Safety Standards Act of 1974, as amended, 42 U.S.C. 5401, et seq. (Act).

I. INTRODUCTION

On February 26,2010, the Federal Housing Finance Agency (FHFA) published a proposed rule to establish 2010-2011 Enterprise ~ffordableH ousing Goals for the two Government Sponsored Enterprises (GSEs) currently operating under FHFA conservatorship. This proposed rule changes both the methodology and criteria for determining compliance with the affordable housing goals, as well as the structure of the goals themselves, based on various factors mandated by Congress.

While MHARR welcomes the express acknowledgment and reaffirmation by FHFA in the preamble to the proposed rule that the GSEs, notwithstanding conservatorship, must — (1) continue to fulfill their core statutory mission, including support for affordable housing; and (2) may not use the conservatorship as a justification for withdrawing support from such market segments. (See, 75 Federal Register No. 38, February 26, 2010) at 9035-9036), it is imperative that FHFA proceed, as expeditiously as possible, to adopt a separate final rule to implement the “Duty to Serve Underserved Markets” (DTS) provision of the Housing and economic Recovery Act of 2008 (HERA), as that duty specifically related to manufactured housing regulated by the Department of Housing and Urban Development.

II. COMMENTS

The manufactured housing industry is today suffering from an unprecedented decline that is due, in significant part, to the virtual unavailability of private financing for manufactured home purchases. In 2006, the HUD Code manufactured housing industry produced 1 17,373 homes. This figure represented a significant decline from 2001 production of 193,120 homes and an even greater decrease from 1998 production levels that approached 400,000 units, but was consistent with previous cyclical industry declines. Since 2007, however, manufactured housing production and sales have fallen dramatically due, in substantial part, to the near unavailability of either public or private consumer financing for manufactured home purchases.

During 2009, the condition of the manufactured housing industry continued to deteriorate, as production and sales of new HUD Code manufactured homes fell to 49,683 homes, the lowest production level in the industry’s history. This represents a nearly 90% decline in production over a period of ten years and reflects a catastrophic loss of affordable, non-subsidized housing opportunities for American consumers. It also reflects the closure of production facilities — from approximately 420 in 1998 to 120 today – with the resultant loss of thousands of manufacturing jobs and thousands more jobs lost in other sectors of the industry, including component suppliers, home installers, home transporters, retailers, manufactured housing communities, and finance and insurance providers.

In large measure, the unavailability of private purchase-money financing that has fueled this unprecedented decline, is due to policy decisions implemented earlier this decade by the GSEs which effectively discriminate against HUD Code manufactured homes and manufactured housing consumers. As a consequence of these policies, manufactured housing obligations — which had long been a minimal component of the GSEs’ portfolios notwithstanding sustained growth in the broader housing economy — have now been drastically reduced to less than one percent of the total business portfolios of both GSEs. This has not only constricted the availability of liquidity necessary to support an economically viable level of private financing for manufactured home purchases, but is also relevant to the GSEs’ failure to meet affordable housing goals in prior years, as documented by FHFA.

Discrimination by the GSEs against manufactured housing and manufactured housing consumers is also inconsistent with federal housing policy as expressed by Congress in the Manufactured Housing Improvement Act of 2000. That legislation provides, in relevant part, that one of its primary goals is to “facilitate the availability of affordable manufactured homes and to increase home ownership for all Americans.” (See, 42 U.S.C. 5401(b)(2)). The promise of affordable manufactured housing for American families, however, means little if the private financing necessary to purchase a HUD Code home is either unavailable, or its availability is severely and unreasonably restricted.

Consequently, while MHARR acknowledges the challenging market conditions and related factors cited by FHFA in support of the proposed 2010-201 1 goals, the difficulties facing the entire housing market and the broader economy make proper GSE support for affordable housing even more important. With historically high foreclosure rates, significant unemployment and reductions in family income, more Americans, not fewer, will need and will be seeking home-ownership and housing opportunities — such as those provided by manufactured housing — that are inherently affordable. The GSEs were formed to — and statutorily charged with — providing such liquidity. That mission, in the current economic climate, is more important than ever.

More importantly, going forward, it is essential that FHFA distinguish between the broader affordable goals addressed by this proposed rule and the specific congressional DTS mandate. Under that provision, Congress, recognizing that the GSEs were not properly serving and not fulfilling their mission to HUD Code manufactured housing consumers, directed the GSEs to “develop loan products and flexible underwriting guidelines to facilitate a secondary market for mortgages on manufactured homes for very low-, low-, and moderate-income families.” (Emphasis added).

DTS thus represents a finding and declaration by Congress — independent of the broader affordable housing goals addressed by the present proposed rule — that the GSEs have not and are not doing enough to serve the manufactured housing market, as well as a remedy, directing the GSEs to do more. Given this specific congressional mandate and directive, any final DTS rule should go beyond the general Enterprise Affordable Housing Goals in mandating and evaluating the participation of the GSEs in the manufactured housing finance market. MHARR has previously documented its view regarding the substance of an appropriate DTS program in comments filed in 2009 pursuant to an FHFA Advance Notice of Proposed Rulemaking specifically regarding DTS. MHARR, accordingly, urges FHFA to act expeditiously to develop and publish a proposed regulation to implement DTS that will expand the role of the GSEs in providing necessary liquidity to support private financing for HUD Code manufactured housing purchases. This will assist the GSEs in meeting broader Enterprise Affordable Housing Goals, provide much needed relief for consumers who cannot currently obtain private financing, and help turn the industry (and the hundreds of thousands of Americans it employs) toward economic recovery.

We hope that these comments are helpful for purposes of the present docket and will help lead to the proper and expeditious implementation of separate DTS regulations.

Sincerely,
Mark Weiss
Senior Vice President
Manufactured Housing Association for Regulatory Reform
1331 Pennsylvania Avenue, N. W.
Suite 508
Washington, D.C. 20004
(202) 783-4087 (Office)
(703) 509-9489 (Direct)
(202) 783-4075 (Fax)
mmarkweiss@aol.com (Email)
cc: Mr. Danny Ghorbani, MHARR