On July 10, 2019, the Arlington, VA based Manufactured Housing Institute (MHI) published the following.  It will be provided verbatim.  It will be followed by our MHProNews analysis.

 

 

Seth Appleton and Hunter Kurtz Begin Key Roles at HUD

On June 28, 2019, Seth Appleton was sworn in as the Assistant Secretary of Policy Development and Research at the U.S. Department of Housing and Urban Development (HUD), alongside Hunter Kurtz who is now the Assistant Secretary of Public and Indian Housing. MHI, along with a coalition of housing industry organizations, supported both nominees throughout their confirmation processes by submitting numerous letters to the U.S. Senate advocating for their immediate confirmations. On June 20, 2019, the Senate confirmed both Appleton and Kurtz.

In his new position as Assistant Secretary of Policy Development and Research, Appleton will oversee the Office of Policy Development and Research (PD&R), which is the unit at HUD primarily responsible for housing research and data analytics. PD&R’s core functions are to: collect and analyze national housing market data; conduct research, program evaluations, and demonstrations; and provide policy advice and support to the HUD Secretary and program offices. With regards to manufactured housing, PD&R conducts research on innovative building techniques, new rules, and other regulatory requirements, including land use policies, zoning regulations, and community opposition – all of which affect housing prices. PD&R is also responsible for evaluating the policy and economic impact of the Manufactured Housing Consensus Committee’s recommended updates to the HUD Code before they are published in the Federal Register. On behalf of our industry, MHI routinely participates in roundtables, conference calls, and other meetings with PD&R to ensure that manufactured housing is always part of the conversation when researchers are looking at opportunities to increase the supply of affordable housing in America.

Mr. Appleton has a track record of support for manufactured housing going back to his tenure on Capitol Hill. He previously served as Chief of Staff to Representative Blaine Luetkemeyer (R-MO), the former Chairman of the House Financial Institutions and Consumer Credit Subcommittee. Under Mr. Appleton’s tenure, Representative Luetkemeyer strongly advocated for manufactured housing issues and helped shepherd the Preserving Access to Manufactured Housing Act through the U.S. House of Representatives on multiple occasions. During the legislative process, Representative Luetkemeyer delivered persuasive remarks about the federal regulations that made it difficult for consumers to obtain financing for manufactured homes during Committee hearings and on the House floor. Because of his strong support and advocacy, Representative Luetkemeyer was able to ensure the provision that manufactured housing retailers and sellers did not need to be loan originators was included in S. 2155, the “Economic Growth, Regulatory Relief and Consumer Protection Act,” which was signed into law by President Trump.

 

In his new position as Assistant Secretary of Public and Indian Housing, Hunter Kurtz will oversee the Office whose role is to ensure safe, decent, and affordable housing and create opportunities for residents’ self-sufficiency and economic independence. Prior to assuming this position, Kurtz served as the Deputy Chief of Staff for Policy and Programs at HUD.

Kurtz has years of experience in the field of housing and community development, including previously serving at HUD in the Office of Congressional and Intergovernmental Relations and the Office of Community Planning and Development. Kurtz began his career at HUD in 2006 in the Office of Community Planning and Development and in 2009 worked as a community planning and development specialist at the Department until 2015 when he became the Deputy Director of the Department of Housing and Revitalization for the City of Detroit

MHI congratulates both appointees on their new roles and looks forward to working with them to ensure that manufactured housing is an integral part of HUD’s efforts to support unsubsidized, attainable homeownership opportunities.

If you have any questions, please contact MHI’s Government Affairs Department at MHIgov@mfghome.org.

Their version as provided to their readers is found at this link here. For the sake of their attorneys, that and this analysis are being provided under fair use guidelines for media, see that at this link here.

 

Analysis and Commentary

For the purposes of this report, let’s stipulate for discussion’s sake that what they provided is factually accurate. What was their purpose in sending this out to their readers and members?

The answer to that is suggested in their ‘got clout’ mantra, and in their related claims to have influence with people in key positions.

It is arguably to impress those who are busy and may not take time to digest what they’ve demonstrably accomplished.  As Mark Weiss, JD, put it earlier this year, it is part of he “Illusion of Motion.”

This emailed posturing by MHI to their members is not seen on their website, nor on others as the screen capture below reflects. That is why it appears to be posturing for readers and their members. Why don’t they do as several other trade associations do? Why don’t they post their own emails and ‘news’ on their own website?

 

 

There are several points to be made here, regardless of someone’s feelings or thinking about MHI.

·        MHI either is effective, ineffective, or a mix of those outcomes.

·        Their effectiveness must be pondered from the perspective of the biggest firms in manufactured housing. Why? As a long-time MHI member told MHProNews, if Clayton, Cavco, Skyline-Champion and a relatively small numbers of community operators decided to walk away from MHI, the organization would rapidly cease to exist. Indeed, as veteran industry professionals recall, in the post 2000 meltdown, MHI was close to bankruptcy. If you wonder why they tell readers from time to time that they are financially strong, look no further than that point.  They were close to financial insolvency, until they were reportedly bailed out.  We’ll examine that another time.

·        So, effectiveness, as longtime MHI award-winning member Marty Lavin has phrased it, is what benefits their ‘big boy’ members.

·        When MHI leaders praise their president and CEO Richard ‘Dick’ Jennison, or anyone else, it must be viewed through the lens of the agenda, open or hidden, of the speaker and those ‘big boys.’

MHI has been making photo ops and videos with key federal and state officials an increasingly evident feature of their messaging to members.  But if MHI has clout, how have they used it?

·        Where is the full implementation of the Duty to Serve on all manufactured homes, not on just a select few that Clayton Homes and their camp followers wanted.

·        If MHI has clout and performance, why are shipments down 9 straight months year over year?

·        Why isn’t MHI pressing for HUD to use their clout on enhanced preemption of HUD Code manufactured homes in situations like those shown below?

Texas, Florida Cities Plan Manufactured Home Ban, Legacy Housing, FMHA, Lance Inderman/Jessup Housing React

·        If MHI had clout, why wasn’t Preserving Access ever passed?

There are several examples of a lack of MHI effectiveness…

…from the perspective of most MHI and industry members. But it arguably is effective for those who want to consolidate the industry.

 

It’s troubling, but what explanations can be offered as to the contrary?

Once more, MHI and others in the Omaha-Knoxville-Arlington axis will be given an opportunity to respond to this in writing, on stage and on camera, or wherever makes good mutual sense.  But if recent months are any evidence, don’t hold your breath.

Several state associations will respond, albeit at times off the record.  The same is true for corporations, NAMHCO, or MHARR.  What is the Omaha-Knoxville-Arlington axis afraid of anyway?  If they had a good reply, why not provide it?

Try this on for size. With Democrats and Republicans alike taking greater interest in manufactured housing, the odds of someone being called into to testify under oath grows. Do you think they want to be revealed as self-contradictory?

If MHI has influence, they have an odd way of showing it.  If MHI wants to flex their muscles and impress the industry,

·        get HUD to fully and properly implement the Manufactured Housing Improvement Act of 2000.

·        As a key, but not only, part of the above, have a non-career administrator appointed and have HUD flex their muscles on Enhanced Preemption with local zoning roadblocks.

·        Get the FHFA to compel the Government Sponsored Enterprises (GSEs) of Fannie Mae and Freddie Mac to fully implement the Duty to Serve (DTS) manufactured housing on ALL HUD Code manufactured homes, not only a select, experimental ‘new class’ of housing that made no sense, given the ability to build modular housing akin to them.

·        Get FHA to modify the 10/10 rule on Title I loans,

·        Get other useful modifications on Title II, VA, USDA on land-lease, with the proper consumer safeguards.

·        Get antitrust law enforced and break up the FAANG companies, Microsoft, and Berkshire Hathaway (#DeFaangBM).

·        Properly educate the public, advocates, and lawmakers by using their media resources.

That can be summed up with this phrase: Enforce good existing laws and use regulatory reform to implement other items as noted. Doing that would fuel a surge in manufactured housing investing and could turn millions of renters and others into manufactured homeowners.

But they could have done that years ago, if they wanted to, right?  When former President Barack Obama was in the Oval Office, Warren Buffett had access to the 44^th American Chief Executive. Buffett’s grandson was in the White House. Democrats controlled the Congress for 2 years. If they wanted the law enforced, that was the time to do so, right?

Facts and logic are stubborn things.

That’s the midday installment of manufactured housing “Industry News, Tips, and Views Pros Can Use” © where “We Provide, You Decide.” © ## (News, analysis, and commentary.)

Submitted by Soheyla Kovach for MHProNews.com.
Soheyla is a managing member of LifeStyle Factory Homes, LLC, the parent company to MHProNews, and MHLivingNews.com. Connect with us on LinkedIn here and here.

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