As was referenced in MHARR’s July 26, 2018 memorandum concerning its recent meeting with HUD Assistant Secretary-Federal Housing Commissioner, Brian Montgomery, HUD has now published formal notice of an upcoming meeting of the Manufactured Housing Consensus Committee (MHCC) in the July 31, 2018 edition of the Federal Register (see, copy attached).
The meeting, scheduled to be held from September 11 through September 13, 2018 in Washington, D.C., will be the first meeting of the MHCC – of any kind – in more than a year-and-a-half, with the last telephone conference meeting of the MHCC having been held in December 2016 and the last in-person MHCC meeting having been conducted in October 2016.
Significantly, notwithstanding indications (and assurances) at MHARR’s July 25, 2018 meeting with Commissioner Montgomery that aspects of HUD’s “top-to-bottom” regulatory reform process for the federal manufactured housing program pursuant to Trump Administration Executive Orders (EO) 13771 and 13777 would be presented to – and considered by – the MHCC at this meeting, the bare-bones meeting agenda contained in the Federal Register announcement gives no specific indication of any such activity. Instead, the “tentative agenda” included in the meeting notice refers to a continuing “Review of Current Log and Action Items,” even though the last “log” of proposed code changes posted at the federal program website – dated April 2018 – indicates that the MHCC (with just one exception) has already taken “final action” on all pending log items and submitted corresponding recommendations for action by HUD.
That said, it remains to be seen: (1) what – if any – presentation or review of proposed regulatory reform actions will be brought to the MHCC for consideration at this meeting; and/or (2) what other new proposals or action items may be brought to the Committee – if any – for consideration at this meeting, given HUD’s failure, to date, to publish or make those materials available to program stakeholders for review priorto the MHCC meeting and possible input or comment to the MHCC, at the meeting, regarding their specific content. Therefore, while further HUD action on this point is certainly possible prior to the September meeting, it remains to be seen whether such action – if any — will provide either the Committee and/or program stakeholders with sufficient time and information to fully and completely evaluate any such proposals in advance of the meeting, in order to provide meaningful, substantive input.
Given the past history of the federal program in similar situations, MHARR will closely monitor this matter and will take further steps as necessary to ensure the integrity of the MHCC process, while keeping the industry apprised of further developments as warranted.