March 21, 2017

Dear Sir or Madam:

The following comments are submitted on behalf of the Manufactured Housing Association for Regulatory Reform (MHARR).  MHARR is a Washington, D.C.-based national trade association representing producers of manufactured housing regulated by the U.S. Department of Housing and Urban Development (HUD) pursuant to the National Manufactured Housing Construction and Safety Standards Act of 1974, as amended by the Manufactured Housing Improvement Act of 2000 (42 U.S.C. 5401, et seq.).  MHARR’s members are primarily smaller and medium-sized independent producers of manufactured housing located throughout the United States.

In January 2017, the Federal Housing Finance Agency (FHFA), as an adjunct to its December 29, 2016 final rule implementing the Duty to Serve Underserved Markets (DTS) provision of the Housing and Economic Recovery Act of 2008 (HERA), issued a Request for Input (RFI) seeking “public input on considerations that Fannie Mae and Freddie Mac (the Enterprises) should include in their determinations of whether to include manufactured home chattel loan pilot [programs] in their Duty to Serve Underserved Markets Plans, and if so, how such pilots could be designed, taking into account policy and safety and soundness considerations.” The RFI contains five areas of inquiry and related questions. In connection therewith, the RFI provides: “Interested parties may address any or all of the following subjects and questions, in addition to raising and addressing other issues related to the Enterprises pursuing a chattel loans pilot.”

For its response to the RFI, MHARR attaches and hereby incorporates by reference herein: (1) the statement of its President and CEO, Mark Weiss, as offered and presented to FHFA at its February 8, 2017 DTS/FHFA “listening session” in Washington, D.C. (attached); (2) its written DTS statement as offered and presented at the January 25, 2017 DTS/FHFA “listening session” in Chicago, Illinois (attached); and (3) its March 15, 2016 written comments on the December 18, 2015 FHFA-proposed DTS implementation rule (previously filed in the DTS rulemaking docket).

In relevant part, MHARR, in these documents, rejects the concept of a limited, discretionary manufactured home chattel “pilot program” or “programs” as authorized by the December 29, 2016 FHFA final rule. Instead, as is further addressed, detailed and explained therein, MHARR seeks “a revised and reformed DTS implementation rule [that would] specifically authorize and mandate a series of Enterprise-securitized chattel loans in volume, staggered over multi-year periods, so that they can be analyzed and evaluated every three years for any adjustment as warranted for the next series. Given the high demand by very low, low and moderate-income consumers for such Enterprise-securitized loans — and the estimated 250,000 empty spaces in existing manufactured home communities – this type of program would not only meet the full DTS obligations of the Enterprises, but would make affordable homeownership immediately available to millions of Americans.”

MHARR otherwise restates and reaffirms the comments set forth in the above-referenced and incorporated documents.

Sincerely,
Mark Weiss
President and CEO

cc: Manufactured Housing Industry Post-Production Members (without attachments)