Finance Issues Addressed at High-Level Meeting

A high-level summit meeting to address the financing issues that have fueled a prolonged industry decline and unprecedented hardships for consumers, was co-hosted by Congressman Joe Donnelly (D-IN) and HUD Assistant Secretary for Housing-Federal Housing Commissioner David Stevens in Elkhart, Indiana on June 2,2010. The meeting brought together industry leaders and high-ranking officials of government agencies -- including HUD, the Federal Housing Administration (FHA), the Government National Mortgage Association (GNMA) and the Federal Housing Finance Agency (FHFA) -- with a role in providing or supporting public and/or private consumer financing for manufactured homes

At the outset, both Congressman Donnelly and Commissioner Stevens acknowledged the important role of HUD Code manufactured housing in providing affordable non-subsidized home-ownership for all Americans and particularly for lower and moderate-income families. In addition, Commissioner Stevens stressed that the Administration is dedicated to affordable housing and working with the industry to ensure that affordable manufactured housing is available for the nation's consumers, Commissioner Stevens then addressed a number of key issues regarding public financing and the HUD Title VI program:

• The Commissioner announced that the Federal Housing Administration (FHA) would release a further Title I Mortgagee Letter on June 2, 2010, to address the final issues remaining for the full implementation of the Title 1 improvements and reforms adopted by Congress in the Housing and Economic Recovery Act of 2008 (HERA). (See article below for further detail).
• The Commissioner and officials of GNMA, indicated that with the June 2, 2010 Mortgagee Letter, the stage is set for GNMA to issue updated guidelines soon for the securitization of manufactured housing obligations and the qualification of participating finance institutions;
• The Commissioner discussed the possible development of voluntary guidelines by the industry to improve the FICO scores and qualifications of financing applicants to bring them closer to purchasers of other types of homes, and the potential inclusion of such guidelines in a future rule if they are found to be effective; and
• The Commissioner detailed the reorganization of the Office of Manufactured Housing and Regulatory Affairs, including the role of the new Associate Deputy Assistant Secretary, Ms. Teresa Payne, and its place within the newly-established Office of Risk Management and Regulatory Affairs to be headed by Chief Risk Officer, Mr. Bob Ryan.

In another major announcement affecting private financing, officials of the Federal Housing Finance Agency (FHFA), announced that a long-awaited proposed rule to implement the "duty to serve" provision of HERA will soon be published in the Federal Register for public comment. (see article attached for further detail).

Following comments by the participating government officials, both national industry organizations - MHARR and MHI - presented detailed information regarding the finance issues affecting the industry and its consumers, and the toll that the nearunavailability of either public or private financing has taken on the production of manufactured homes, employment within the industry and, most importantly, the ability of the industry to provide affordable home-ownership. MHI provided the summit participants with a detailed visual presentation on these issues, while MHARR provided the participating government officials with corresponding package of written position papers addressing these matters. (see, copy attached).

Both industry organizations, as well as individual industry representatives at the summit meeting, specifically noted in their presentations that both national industry organizations agree on the need to restore and expand the availability of public and private financing and on the need for a level playing field for the industry and manufactured housing consumers.

On a more specific matter concerning financing and the industry's post-2000 reform law homes, MHARR Chairman Edward J. Hussey (Liberty Homes, Inc.) in his presentation, addressed and directly refuted the contention, contained in a January 16, 2010 letter to Congressman Travis Childers (D-MS) by HUD General Counsel Helen Kanovsky, that improved "quality control" within the HUD program would help expand the availability of financing for manufactured homes. Mr. Hussey pointed out that the quality of post-2000 reform law manufactured homes is comparable to - if not better than -- any other type of home on the market and that the recent unavailability of consumer financing has been a function of problems affecting the credit markets and the broader economy, rather than any deficiency in manufactured housing.

Based on ideas presented and discussed at the meeting, there will be further exploration and follow-up on a number of issues, including, but not limited to:

• FHA program guidelines based on a "best practices" approach to improve portfolio performance;
  
• Further examination of lien protection based on "best practices";
  
• Separating manufactured housing from site-built housing for reporting purposes;
  
• Future examination and consideration of appraisal-related issues; and
  
• Addressing manufactured housing as an asset not only in providing affordable housing, but also jobs and environmentally-conscious construction that produces less construction waste than other segments of the residential construction industry.

Given the importance of proper more readily-available financing to the recovery and ultimate expansion of the manufactured housing industry, and the difficulties that the industry and consumers of affordable housing currently face, both Congressman Donnelly and Commissioner Stevens are to be commended for convening this roundtable meeting, which has raised financing to the policy level, where it can be most effectively addressed and resolved. MHARR will continue to pursue solutions to these issues based on principles, concept and approaches that enjoy wide agreement and support among all industry members (particularly manufacturers) and consumers.

MHARR is a Washington D.C.-based national trade association representing the views and interests of producers of federally-regulated manufactured housing.

PRESENTATION OF THE MANUFACTURED HOUSING ASSOCIATION FOR REGULATORY REFORM
TO
THE MANUFACTURED HOUSING ROUNDTABLE

JUNE 2,2010
ELKHART, INDIANA

MANUFACTURED HOUSING PUBLIC AND PRIVATE CONSUMER FINANCING

Click Here to Download This Document

Prepared By:
The Manufactured Housing Association for Regulatory Reform
1331 Pennsylvania Avenue, N.W. Suite 508
Washington, D.C. 20004
Tel. (202) 783-4087
Fax: (202) 783-4075
Email: This e-mail address is being protected from spambots. You need JavaScript enabled to view it

For more information on this important issue:

FHFA Proposes Rule on Fannie Mae and Freddie Mac Requirements for Underserved Markets

Summit Meeting Addresses Industry Finance Issues

Stage Set for Action on Title I Moratorium

Long-Awaited "Duty to Serve" Proposal Unveiled

Ken Rishel report on the Manufactured Housing Roundtable