For the second time in two months, on May 26, 2011, MHARR officials (the Chairman, Vice Chairman and Immediate Past Chairman) and staff held meetings in Congress (see below), followed by a meeting with Acting HUD Assistant Secretary for Housing – Federal Housing Commissioner Bob Ryan and career officials of …
MHARR Officials Meet with Federal Housing Commissioner Read More
MHARR has received several inquiries regarding the details of Representatives John Campbell’s (R-CA) and Gary Peters’ (D-MI) GSE reform legislation that they unveiled on May 12, 2011. The below material (including the accompanying sites) will provide the relevant details of this legislation, which is a must-read for the housing, finance …
APRIL 28, 2011 VIA FEDERAL EXPRESS Regulations DivisionOffice of General CounselU.S. Department of Housing and Urban DevelopmentRoom 10276451 Seventh Street, S.W.Washington, D.C. 20410-0500 Re: Docket No. FR-5506-N-01 Reducing Regulatory Burden — Retrospective Review Under E.O. 13563 Dear Sir or Madam: The following comments are submitted on behalf of the …
MHARR Comments on HUD’s Failure to Implement Obama’s Regulatory Fairness Order Read More
05-04-2011 TO: MHARR MANUFACTURERS MHARR STATE AFFILIATES FROM: MHARR RE: INCREDIBLY BIASED AND MISLEADING JOINT HUD-CDC “REPORT” NOW BEING CIRCULATED As you may be aware, a joint “report” issued by the Department of Housing and Urban Development and the Centers for Disease Control (CDC), entitled “Safety and Health in …
Incredibly Biased and Misleading Joint HUD CDC Report Now Being Circulated Read More
MAY 6, 2011 by Danny Ghorbani — Capping a process that began a decade ago with an MHARR Petition for Rulemaking, HUD has published proposed revisions to its Subpart I notice and correction regulations. That proposal, which is the subject of comprehensive MHARR comments, presents, at best, a mixed …
APRIL 14, 2011 TO: MHARR MANUFACTURERS MHARR TECHNICAL REVIEW GROUP (TRG) MHARR AFFILIATED STATES FROM: DANNY D. GHORBANI RE: MHARR COMMENTS ON HUD PROPOSED SUBPART I RULE Attached for your review and information is a copy of MHARRs comprehensive comments on HUDs February 15, 2011 proposed rule to amend …
by Danny Ghorbani — HUD’s recently released Fiscal Year 2012 budget and appropriations request for the federal manufactured housing program shows why Congress needs to carefully scrutinize program spending and demand accountability from HUD regulators for the misdirection of funds previously appropriated by Congress. The time for the industry to press for such intervention, moreover, is now, when all aspects of the program budget are subject to oversight by Congress based on section 620 of the Manufactured Housing Improvement Act of 2000, and not later, during a HUD administrative rulemaking on higher label fees, when the only issue will be the amount of the increase and industry objections are unlikely to receive any kind of hearing.
Washington, D.C., April 7, 2011 — According to official statistics complied on behalf of the U.S. Department of Housing and Urban Development (HUD), manufactured housing production has continued to significantly decline in 2011. In January 2011, 2,796 HUD Code homes were produced, down from 3,210 homes in January 2010, representing a year-over-year decline of 12.89%. This trend continued in February 2011 with 2,892 HUD Code homes produced, down from 3,463 homes in February 2010, representing a year-over-year decline of 16.5%. To date, therefore, 2011 production has declined by an average of 15%. This follows on the heels of record low annual production of 49,275 homes in 2010, a decline of .8% below the previous record low of 49,683 units in 2009. This represents a drop of almost 90% since 1998, when nearly 374,000 manufactured homes were produced, and the 13th consecutive year of production declines for the only segment of the housing industry that is comprehensively regulated by the federal government.
Washington, D.C., April 4, 2011 — The outgoing Chairman of the Manufactured Housing Association for Regulatory Reform (MHARR), Edward J. Hussey, has become only the third person in the 26-year history of the Association to receive its coveted “Honor and Recognition Award.” The award, a commemorative plaque and a …
Hussey Becomes Third Recipient of Coveted MHARR Award Read More
Washington, D.C., April 4, 2011 — The members of the Manufactured Housing Association for Regulatory Reform (MHARR), at their 2011 Annual Meeting in Tunica, Mississippi, have elected Mr. John Bostick, President of Sunshine Homes, Inc., Red Bay, Alabama, to become the new Chairman of the Association. Mr. Bostick succeeds …
As a follow-up to our March 3, 2011 Memorandum, set out below, for your review and information, are copies of the initial response of HUD’s career program administrator, Teresa Payne (on behalf of HUD Assistant Secretary David Stevens) to MHARR’s January 19, 2011 letter regarding the implementation of Executive Order …
Over the past twelve years, the manufactured housing industry has been decimated. Every segment of the industry has felt the pain as production has tanked, plants have closed and jobs have disappeared. The impact has been no less harsh for consumers — particularly lower and moderate-income families — many of whom have seen their dreams of home-ownership erased by the same factors propelling the industry’s decline. Through good economic times and bad, while the market for other types of housing has been up and down, the trajectory of the HUD Code industry for over a decade has gone in one direction — downward.
Washington, D.C., February 23, 2011 — The February 2011 release of the Fiscal Year 2012 budget and appropriations request of the HUD manufactured housing program underscores the urgent need for intensive congressional scrutiny, examination and oversight of that runaway budget, as well as direct accountability by HUD regulators for the misdirection of funds previously appropriated, as already called for by the Manufactured Housing Association for Regulatory Reform (MHARR).
Attached is a copy of a HUD proposed rule to amend Subpart I (Consumer Complaint Handling and Remedial Actions) of the Procedural and Enforcement Regulations, published in the Federal Register on February 15, 2011. It is important that you carefully review this proposed rule with your regulatory, technical and legal personnel for any possible input, as MHARR will be submitting comments to HUD on behalf of manufacturers. In addition, both this proposal and MHARR’s analysis of its elements and potential impact will be fully addressed at MHARR’s upcoming meeting in Tunica, Mississippi. Written comments on the proposed rule are due on or before April 18, 2011.
Washington, D.C., January 26, 2011 – The Manufactured Housing Association for Regulatory Reform (MHARR) has submitted testimony to a key congressional committee detailing the drastic decline of the federally-regulated manufactured housing industry and urging Congress to intervene and conduct further oversight into the U.S. Department of Housing and Urban Development …
MHARR Testimony Urges Congressional Intervention to Revive Industry Read More
An important aspect of the decline of the federal manufactured housing program that has largely gone under the radar in recent years and threatens now to subject the industry and consumers to a mountain of costly new de facto regulation, is the ever-expanding relationship between the program and paid contractors, while the role, involvement and funding of state agencies has correspondingly diminished. Consequently, MHARR is now moving to address such funding aspects of the federal program with Congress.
Washington, D.C., December 14, 2010 – Ten years after the enactment of the landmark Manufactured Housing Improvement Act of 2000 – watershed legislation passed unanimously by both houses of Congress in order to complete the transition of manufactured housing from the “trailers” of yesteryear to legitimate “housing” and ensure its parity with all other types of homes – the promise of that law, for both the industry and consumers, remains unfilled.
WASHINGTON – Congressman Spencer Bachus (AL-6), Chairman-elect of the House Financial Services Committee, today announced his appointments for committee leadership positions in the 112th Congress. In addition to naming the vice chairman and subcommittee leaders, Bachus announced plans to modify subcommittee jurisdictions to promote a more efficient and balanced work-load for committee members.
The Manufactured Housing Consensus Committee (MHCC), at its October 2010 meeting, tabled a HUD-MHI (Manufactured Housing Institute) proposal for an “as needed” federal fire sprinkler standard (one that supposedly would apply where sprinklers are voluntarily installed by the manufacturer or required for all homes by state or local law). Actually, sprinklers in manufactured homes should not even be an issue, and HUD, judging by recent comments, being unwilling to implement the enhanced preemption of the 2000 reform law, would be just as happy to stay out of the matter. But it is being drawn into this fray to appease a few larger companies that – spooked by local sprinkler standards in some Western states – are pushing this “as needed” shortcut. Predictably, however, it will come back to haunt the industry and its consumers. As explained below, therefore, the MHCC should deep-six this flawed shortcut.
Washington, D.C., November 29, 2010 – The Manufactured Housing Association for Regulatory Reform (MHARR) has called upon the General Counsel and Inspector General of the Department of Housing and Urban Development (HUD) to intervene personally to ensure that the Department fully discloses responsive documents, as required by law, to a request filed under the Freedom of Information Act (FOIA) that it has thus far been reluctant to answer. That November 2009 FOIA request was filed in order to obtain documents and information regarding the apparent involvement of HUD officials (and agents) in closed-door meetings and related activities where a dramatic ongoing expansion of the in-plant regulation of manufactured housing producers was planned, developed and/or modified, contrary to relevant law.
