“A proposed Federal Housing Finance Agency (FHFA) “Draft Strategic Plan for Fiscal Years 2018-2022” barely mentions implementation of the “Duty to Serve Underserved Markets” (DTS) by the two Government Sponsored Enterprises (GSEs), even though, according to the implementation plans submitted by those organizations to FHFA earlier this year, key aspects of the GSEs’ implementation of DTS (as deficient as they are, as stressed by MHARR in its written comments on those plans) are slated to occur over that period.”
So said Mark Weiss, President and CEO of the Manufactured Housing Association for Regulatory Reform (MHARR).
Weiss said in a release to MHProNews that, “In its only reference to DTS, the draft Strategic Plan, published by FHFA on September 27, 2017, states:
““FHFA will meet its statutory responsibilities to issue regulations as needed defining the regulated entities’ Housing Goals and Duty to Serve obligations for the Enterprises and FHFA will annually monitor the Enterprises, Housing Goals and Duty to Serve performance,” quotes MHARR’s CEO.
The FHFA’s “…bare-bones reference, however, provides no assurances or commitment whatsoever to ensuring that the GSEs will fully implement DTS – including market-significant securitization and secondary market support for the chattel loans that comprise the vast bulk of manufactured home consumer financing – during the time-frame of the draft Strategic Plan, which will conclude a full 14 years after Congress’ adoption of DTS as part of the Housing and Economic Recovery Act of 2008 (HERA),” said Weiss.
“MHARR, accordingly, will submit comments to FHFA seeking a more specific commitment to the full and proper implementation of DTS with respect to manufactured housing and manufactured housing chattel loans in particular, as well as a detailed and updated time-line for that full and proper implementation to occur,” Weiss said.
MHARR said that comments on the FHFA draft 2018-2022 Strategic Plan must be submitted to the agency no later than October 27, 2017.
In a related story for an early roll out of a GSE plan in a community, click here. ## (News, analysis, commentary.)
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