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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.)

Exhaustion Sets In

August 8th, 2014 1 comment

I’m exhausted, Jerry, exhausted I tell you. “Exhausted, Marty Boy, why?” Well there are many reasons, and in trying to sort it all out, I’ve exhausted my feeble brain.

I speak of course about the state of the industry. It starts with L. A. ”Tony” K, the MHProNews impresario, whose boundless industry enthusiasm doesn’t quit. Now all this, mind you, as we scrape along on an annual shipments level which in the past we equaled and surpassed in a single month.

Getting your head around that enthusiasm is hard to sort out. So many reasons why MH should be great but woeful results, that’s what is exhausting me.

Story Time

Let me tell you a little story. Sometime along the mid 2000’s, say 2006 or 2007, I was invited to join Urban Land Institute, ULI, a well-known and respected real estate trade association/think tank. It is populated by some of the largest and most powerful real estate interests, a pretty awesome “who’s who” of the Big Boys in real estate.

Inside Trailerville then were people who had come to our industry from the real estate industry and thought manufactured housing communities was a land use that should be represented at ULI. An MH council was formed and I was invited, along with 30+ others, to join and was frankly flattered to accept. ULI has a great reputation.

I started going to the ULI meetings and the MH luminaries were everywhere in the council. My consulting assignment at Fannie Mae at the time profited from my attendance as I was at the industry’s train of thought at the highest level. All good, right?

First Class

Now, understand something, ULI is not MHI or MHARR. ULI goes first class only, no Motel 6’s here. They meet at the very highest level venues, read this to mean “Expensive,” and invite powerful and well-known guests and speakers. Contrasting this with the MH world is eye-popping. If one spends an average of $1,000-$1,500 to attend an MHI convention, ULI seems to come in at $4,000-$6,000 per conference, a not inconsiderable sum for poor boys like me who peeled those dollars out of my own back pocket to attend.

I don’t really mention the cost of attending an MHARR meeting, as long distance phone rates are so low that the occasional MHARR meeting takes little time and virtually no expense. Networking is not really what MHARR is all about.

Lacking Candor

Back to ULI. I found most of the early meetings of the MH council, or whatever its name, a poor version of MHI meetings. While the intent was to foster an exchange of ideas and information from the very highest level of MHdom, the Big Boys were there, but they were all wearing vests so they could keep thoughts and information close to their vests. Even when we were to break for lunch seemed to be a secret. The lack of candid response from participants, who seemed to be going through the motions, disappointed me.

Here we had the greatest minds in MH, but I could gain better industry knowledge and information from the third string attendees from the same companies at an MHI meeting, at 1/3rd to 1/4th the price. I was beginning to waiver about my continued involvement in ULI.

Excited

Then, a ULI conference was announced, where the MH council was to feature a housing study by a prominent economist whose expertise was in housing demand. Whoa! Here’s something I could get my head around. Maybe after the study was presented I could relearn the words to “Happy Days Are Here Again” which in ’06 or ’07 I hadn’t sung since that 1998 post-HUDcode record of 373,000 home shipments. The best industry performance since the 1973 573,000 homes shipped, which had occurred when I was a young man and before the HUDcode.

The economist came, the lights went out, and the demand charts started to flow. Holy craps, Robin, get that song out! It was back. So I kept following the economist’s report carefully and he said the same things then we are still saying today: low cost housing demand, high conventional housing costs, factory built quality, yada yada yada, it was all falling into place, Jerry. Music!

But despite the obvious buy-in by most participants there, their choirboy gleams revealing, I had the uneasy feeling that, just as I do today, of an unfinished report.

Finally, biding my time, as I was as insignificant a participant as there was there, I screwed up my courage and asked the following: Yes, of course, I understand the demand side of the MH equation, but can you tell me, Mr. Eminent Economist, how your exuberant MH sales expectations will be financed?

What?

Huh? He was a housing demand expert. not a finance guru. He hadn’t the slightest idea as to how it would be done. Note that as you hear all the reasons today why MH should be kicking housing azz, that question remains unanswered for the most part.

I could see narrowed eyes around the room directed at me, the thought clear on its face; how dare you, you F’ing Azzhole, challenge Mr. Eminence? He just returned from Mt. Sinai with this report! I though it a fair question to ask, just as I do today.

In 1972 I came into the industry. By the time of the ULI economist meeting I had been kicked around HUDville 35 years. Even with my extraordinarily thick cranium, some knowledge had managed to creep in. By the early 2000’s I had seriously begun to question whether the 1998 shipments top and heavy decline thereafter was a “normal pullback” as had happened frequently in the past. Ah, it will all be back soon was the industry refrain. If I believed that early on, by 2002 there were clear signs to me this time was different, very different.

Not This Time

Working against the industry grain, my study of MH loan performance, the horrific losses suffered by lenders and their investors, got me to thinking the industry had real, long-term problems, from which recovery would be difficult, at best. Did I envision a drop to 50,000 annual HUD shipments? No, I was not born in swaddling clothes.

Further, and this was hard to grasp and accept, since the industry’s real volume emergence in 1969 to the 1998 top, the great volume the industry enjoyed was based on faulty lending losses by most lenders during that period, averaging close to 250,000 annual shipments. I then did the presumptive math on what volume might be with a rigid, but survivable lending regimen, and the numbers were scary low. Not as low as they got, but low.

If you don’t understand the preceding paragraph, read no further until you do. Every time you hear of glowing future prospects for HUD Code homes ask the predictor “How will they be financed?”

Huge industry volume subsidized by huge lender losses. It was an illusion, and it went on so long we all believed it would always continue. When I wrote about this early on in my Newsletter, “Marty’s News and Notes,” I can say the concept was neither generally accepted nor was my writing and lecturing about it well received. Let’s just say I was not the industry’s Favorite Son.

The Book

Fast forward to the present. I just plowed though “Dueling Curves; The Battle for Housing” by Bob Vahsholtz. This is a prodigious work, with the slant from a man well familiar with much of the industry’s early years and a home designer with great home building knowledge. His book is worth reading for the history lesson and for his ideas for reviving the industry going against the site builders.

I sought the answer from his book to my “How will it be financed?” and found in his multiple step program to improve the industry the following on finance:

Accept the penalty of chattel financing or leasing and use it to include such necessities as skirting and exterior storage. Repos should result only from family disasters and crooks. Even better financing – even from local small-town banks – will come with a proven track record. Good affordable homes need no subsidies. Earn a solid reputation from performance rather than waiting for the government to enforce its arguable notions of engineering and financing.”

Very little to argue with there, but will that guide us back to 150,000 to 250,000 HUDcode homes? Annually? I wouldn’t hold my breath.

Phewff

Exhausted, Jerry, exhausted, I say, that questions just exhausts me.

Let’s be clear here, whether I was writing my newsletter, on my consulting assignments, at ULI or MHI, reading Vahsholtz’s book, or discussions with L. A. ”Tony” K and others, THE question which must be answered is to find a way to finance the demand for our housing, at a 150,000 to 250,000 annual sales level. The present sales level just won’t create a stable, growing industry.

So what is it that causes such low sales volume with such high demand? It is because a great part of our demand comes from a tier of people whose credit capabilities make them unfinanciable. Yah, Marty, no big secret there. And when we can finance some of our demand, it comes with a high tariff, an interest rate generally applied by Guido in his transactions These rates, often more than twice and even three times the present rate for site-builds, are needed to ameliorate our high default rates and high losses on defaults.

How?

Let’s deal with the most important reason for this missive; how does MH create demand that has a greater chance of being financed, assuming stupid lending money is not stage left, waiting to enter? How, indeed?

Sometime in the mid 2000’s, the industry commissioned a market study by Roper Associates to ascertain the public’s view of MH. Let me cut through the bull pucks, they reported they had never compiled a study where the industry had such a negative public perception. Oh, man, we finally were the best at something!

A lengthy industry discussion set in, mostly at MHI, meeting after meeting, innumerable committees, and finally a joint meeting with the RV boys to discuss the merit and results of their “Go RVing” campaign. The RV’ers were exuberant about their campaign and urged us in the strongest terms to do our own campaign.

The RV industry had a different problem than MH, just the opposite. Their customer demand came from buyers with good credit, they just weren’t seeing enough of them. On the other hand at MH, we see many customers, enough to fuel many more sales, we just don’t see enough customers with sufficient credit capability. We needed to find a way to get more credit capable people tromping our sales locations. The intent of the Roper study and the follow-up presentation was to lead to a campaign to induce more credit capable buyers to our stores. You know, a campaign to boast the image of the industry and consumer acceptance through increased positive knowledge.

Embarrassment

So meeting after meeting, discussions aplenty, and finally two outcomes, one embarrassing the other catastrophic. The first result was the campaign presentation meeting should have climaxed in a buy-in to move forward with the pros.

The initial presentation was hardly a finished campaign, but the MH Yahoos raised such a ruckus about their vision of what the campaign should be, that it turned into a bitching session of the first water. I saw MOBES who can’t spell “campaign” reaming the pros, turning into a bewildering babble of conflicting ideas. I found that in their other job, sales lot operators and LLC managers, carried out image campaigns, professing to know more than the pros, howling with authoritative criticism. The pros didn’t know MH. They, on the other hand, are the folks who brought you the 40-50,000 annual sales volume, so yes, they know MH.

I met one of the leaders of the campaign presentation after the meeting and he could only shake his head. Yes, not everything they had ever done for others went smoothly, but this was a different order of foolishness. He wondered why they had been hired, as the industry appear to have all the answers. Why, indeed?

Worse

But bad as that was, and yes I was embarrassed to see all of the negative comments I had heard about the industry from outsiders played out before me, the following was worse.

I don’t think I spill any secrets saying a small coterie of individuals run the industry associations. A cocked eyebrow from one of these Brahmins effectively ends any discussion. So the industry opportunity at salvation, already fleeting as all this occurred, tumbled completely due to the well-engrained industry principle, “never do anything that might help a competitor.” And the industry moment when there was still barely enough $$$ muscle to fund an image campaign passed, and with it the last of the passing life rafts.

Succinctly stated, so no one misses my meaning: The industry must find a way to attract a far more capable buyer to our sales locations, or what you presently see is what is likely to prevail. Chances are the image campaign train has left the station and another does not follow close behind.

Bear in mind that some people are prospering under the present scenario. Not too many, but a few, especially those with eyebrow power. Reduction of competition can be salubrious, even if it only consists of a larger portion of a smaller industry. I can only assume as the image campaign was eye browed down, people would know that, or at least suspect it.

No Mojo

So we now find ourselves as an industry with insufficient muscle to fire up any sort of campaign. Some have wondered whether social media or other Internet driven endeavors might substitute for the traditional media campaign we can no longer fuel as an industry, being a real block buster campaign driven by a $20-30 million effort, one that can successfully reach a broad segment of American consumers and educate them about the many advantages we claim for our housing, to attract those folks we so sorely need. Whether the vaunted Internet driven efforts can succeed, I have no knowledge, but I’ve seen no evidence it is being much attempted or positive residue therefrom.

Phone Call

Would it be that in 5 years someone calls me and says “Yah nana nana, you F’ing jerk. See I told you the ad hoc campaigns could work.” I’m not staying up nights in fear.

The years go by, the same silly things are repeated endlessly, about industry promise, the quality of the homes, the future of all homes to be factory built, the far lower cost, and on and on. All great stuff of course, but how do you sustainably finance 150,000-250,000 HUD homes annually? On that, which is the number one issue, the industry is remarkably silent. ##

marty-lavin-posted-on-mhpronews75x75MARTIN V. (MARTY) LAVIN
attorney, consultant, & expert witness
350 Main Street Suite 100
BURLINGTON, VERMONT 05401
802-660-8888 office / 802-238-7777 cell
marty@martylavin.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

Most Manufactured Home Lenders Facing Major Changes Revenue Cliff for Some; Business As Usual for Others

October 10th, 2013 No comments

Wall Street calls this a “revenue cliff.” A sudden drop in cash flow. Dodd-Frank regulations that are set to take effect in mid-January 2014 will result in major changes in guidelines for most of our industry’s major Manufactured Home (MH) personal property lenders.

Among the non-captive lenders, the hardest hit will likely be 21st Mortgage Corp. This lender is expecting a decline of up to 47% in loan volume.

MH Retailers who rely on 21st Mortgage should brace for a sudden revenue loss of 50% – 75% including overall loan volume and an adjustment in origination fees.

This will be devastating for many.

An informal survey of our four credit facilities who primarily bankroll the MH chattel financing aide of the MH industry has revealed major changes expected by most, and business as usual for one lender.

Our lender headquartered in San Antonio, CU Factory Built, is at present reviewing their loan products and origination fee policies. Committees have been assembled, reviewing the new regulations and their guidelines.

Informed industry sources tell MHProNews, who advised us, that CU’s very popular “Step Rate” loan product will likely remain intact, surviving the new regulations.

However, this lender’s origination fee schedule could be cut by up to 50%, more closely resembling the origination fee guidelines of their competitor, Triad Financial Services. The final outcome is yet to be determined.

Thus MH reatailers and loan officers who rely upon CU as their primary lender need to brace for a “revenue cliff.”

Our office has learned that Triad, based in Jacksonville, FL, is expecting “business as usual.” Apparently their loan products and origination fee guidelines have been in compliance with the expected changes in regulations.

Our industry’s other major lender, US Bank, with their regional office based in San Diego, is being very tight-lipped about any changes. Their spokesperson recently declined to comment to us.

The anticipated changes in loan products and origination fees will impact everyone in the MH industry. As loan brokers, quite a few of our employees will be devastated.

Analyzing the changes at this juncture is like shooting a bullet at a speeding train. The best advice we can give you is to dig in and redouble your efforts in support of HR 1779 and related.

If each of us contacts our Congressional Representative and two U.S. Senators in favor of HR 1779 and its planned companion bill, there is still time to avoid this fiscal/financial cliff our retailers and communities who sell are heading towards. ##

dave-shanklin-mhmsm-com.jpegDave Shanklin
Loan Consultant
Empire Homes, Inc.
Santa Rosa, CA
800 – 401 – 3372
NMLS ID # 314463

(Editor's Note: All views expressed on MHProNews are those of the author, and may or may not represent those of publisher or our sponsors. We recommend that you contact the representatives of the lenders you work with and see for yourself what they expect. Take Action! You may also find this related article of interest.)

Are You Ready to Grow?  Ready to Do What it Takes?

June 7th, 2013 No comments

It’s been a tough decade and more for manufactured housing. Before the residential housing meltdown of 2007-08, manufactured housing had it tough already. Half of the homes the industry produced in 1999 to 2000 have since been repossessed. That devastated those customers but also the flood of repos tanked new home production and the number of factories and retailers plunged.

The challenges we face today are in stark contrast to the assets the industry still possesses—excellent products, land zoned for use by MH and market hardened professionals.

So, how do we take those assets and turn the industry around?

Veteran retailer Mike Evans of Centennial Homes of Aberdeen, SD recently laid out his vision to LA Tony Kovach of MHProNews:

  • Identify opportunities that no one else will pursue or they don’t see. (Are you a general contractor or are you giving your margins away to others?)
  • Set your goals within your values.
  • Determine the strategic and tactical plans needed to capture that opportunity.
  • Develop a business plan that uses the 3 resources business owners and managers have to accomplish the task: Capital, Technology and Human Resources.

My only addition to his list is to expand your resources by identifying others that can be your strategic partners. You don’t need to do it all yourself, but you have to be able to fill in the gap between your capabilities and what is needed.

In talking to members, they have product and customers but lack financing. Yes, Dodd-Frank was a blow to installment sales, but there are other ways to finance purchasers. This is an example of where there is need for networking for new finance sources. Successful members are expanding their business by relentlessly talking to bankers, credit unions, and mortgage brokers. One member said, he finally broke through by just being a pest regarding the opportunity that MH finance can be for a local lender.

The days of faxing a loan application and getting an answer by noon are over and are not coming back. If we have all of the elements to rebound, then we need to do what it takes to make it happen. ##

ross-kinzler-wisconsin-housing-alliance-executive-director-posted-industry-voices-manufactured-housing-professional-news-mhpronews-com-75x75.pngRoss Kinzler
Executive Director
Wisconsin Housing Alliance
608.255.3131 voice
608.255.5595 fax

NCC Meeting News Update

January 27th, 2013 No comments

National Communities Council Members:

With the growing need for affordable housing combined with the rapidly evolving regulatory environment, lack of homebuyer financing, and other challenges, our industry has tremendous opportunities at the same time it faces significant hurdles. Both MHI and the NCC have experienced a period of major transition, and with our Washington leadership team now firmly in place, I believe the most important step ahead is to develop a vision and action plan for the NCC that provides the foundation to carry us through the next few years of supporting the industry and servicing our membership. In lieu of the NCC business meeting that has been held traditionally in conjunction with the MHI Legislative Conference and Winter Meeting, at the upcoming meeting the NCC Executive Committee will instead hold a closed planning workshop focused on solidifying the NCC’s vision for the future. Our goal will be to define a vision that ensures the NCC supports MHI’s broader legislative advocacy and marketing outreach efforts, provides the range of services most valuable to the variety of constituents we represent, makes interim NCC meetings more productive for all of our members, and expands our membership to add to our resources and strength as the only MHI division representing community owners.

While the traditional NCC meeting will not be held during the upcoming MHI Legislative Conference and Winter Meeting from February 24-26, I strongly encourage all NCC members to attend this important gathering and support MHI’s advocacy efforts. Our industry has an excellent opportunity for expansion as the housing market recovers, but we need unity and alignment to ensure the regulatory and legislative environment supports our goals. The upcoming Legislative Conference in Washington is the best place to contribute by making our collective industry voice heard on Capitol Hill and helping your legislators recognize our industry’s vital role in providing affordable housing.

As just one example of how your voice can make a difference, the recently released CFPB rules will have a significant impact on community owners and operators, and while the industry did not achieve all of its goals for the new rules, MHI and member efforts clearly had an impact.  For example, within the Qualified Mortgage rules, the CFPB did expand the spectrum of loan amounts and has proposed a qualified mortgage exemption within the new category of “smaller creditors.”  Just today, we are learning that it appears all new manufactured homes may be exempt from the new appraisal requirements for higher-risk mortgages.  While information continues to develop, it is critical that we work together in the legislative process to present industry unity and bring positive results.

The regulatory environment will continue to shift rapidly as additional Dodd-Frank and CFPB rules are promulgated and reform efforts are undertaken. These changes and their impact on your business will be central to the upcoming Legislative Conference, and your participation in MHI’s advocacy efforts is vital to ensuring the best result. I look forward to seeing you in Washington and to working with the NCC’s Executive Committee to lay out a vision that leverages our opportunities, responds to our challenges, and supports your success well into the future.

Sincerely,
David

David B. Lentz
Chairman
National Communities Council

(Editor's Note: this memo was originally sent to NCC members by Vice President Jenny Hodge on Tuesday January 15, 2013. It is reprinted here with permission.)

Follow-up to May 26 Housing Alert

May 27th, 2010 No comments

This Industry Voices post is a follow-up to the May 26 MHI Housing Alert.

MHI members have been working hard on issues related to the SAFE Act, both on the national level and the state level for almost two years, and we appreciate all of your efforts leading up to this point. Based upon some questions MHI is receiving about the Housing Alert of May 26 on the SAFE Act and H.R. 5369, I want to emphasize that the proposed legislation does not seek an outright exemption for retailers of manufactured and modular homes. The language in H.R. 5369 is intended to exempt activities which are administrative and clerical in nature that facilitate the sale of a home to a consumer such as assisting customers in completing paperwork by answering questions, etc. Language in the SAFE Act as originally passed by Congress in 2008 should have accomplished this goal, however, as we all know, the model legislation developed for the states canceled out this exemption.

Initially, our strategy was to advocate for an outright exemption, but Members of Congress indicated that this was not an option. They clearly communicated that the intent of the SAFE Act was to regulate the activities of individuals, not specific professions. The introduction of H.R. 5369 is an important step in bringing the influence of Congressional leadership into the process and will serve as a tool to elevate the need for clarification and relief for this industry before both Congress and HUD. The bill, in combination with over 5,000 comment letters submitted on the proposed rule to implement the SAFE Act, will assist MHI members and states in accomplishing the goal of allowing clerical and administrative tasks to be exempt activities under the SAFE Act.

If you have any questions, please contact us.

Thayer


Thayer Long | Manufactured Housing Institute
2111 Wilson Blvd. Suite 100 | Arlington, VA 22201
Phone: (703) 558-0678 | Fax: (703) 558-0401 | Email: tlong@mfghome.org

Editor’s Note: The Capitol Switchboard, (202) 224-3121 or use:http://www.usa.gov/Contact/Elected.shtml