“Frequently Asked Questions” on HUD Website

In response to numerous inquiries that MHARR has received in recent weeks, industry members should be aware that the HUD manufactured housing program has recently modified the “Frequently Asked Questions” (FAQ) section of its internet website. The FAQ questions and answers now correspond with, repeat and mirror HUD assertions contained in a June 22, 2010 letter to Congress (download copy), which purport to justify and rationalize its failure, over the course of ten years, to fully and properly implement key reform aspects of the Manufactured Housing Improvement Act of 2000.

In the wake of HUD’s June 22, 2010 letter to Congress, which set out a number of new, revised and altered arguments for continuing efforts by program regulators and attorneys to avoid and neutralize the reforms of the 2000 law, Congress requested MHARR to submit a point-by-point response, which the Association did on July 22, 2010 (copy also attached). This response not only refutes HUD’s core arguments on each issue addressed, but also highlights factual errors and incorrect assumptions underlying various HUD positions – such as those pertaining to the crucial role and authority of the Manufactured Housing Consensus Committee (MHCC) – which HUD has systematically downgraded and undermined in recent years.

Because HUD’s June 22, 2010 letter had been directed to Congress, in response to a specific congressional inquiry regarding the implementation of key aspects of the 2000 reform law, MHARR had similarly directed its point-by-point industry response and refutation specifically to Congress. Now, though, that HUD is extensively publicizing the assertions contained in its June 22, 2010 letter – casting those assertions as the supposed final word on the 2000 reform law implementation issues that they address, with no indication that those assertions have been disputed and refuted – industry members and all those with an interest in affordable manufactured housing should be aware that: (1) those assertions and contentions are strongly disputed; (2) that there is an industry response and counter to each of HUD’s assertions; and (3) that HUD Code manufacturers will continue – and will intensify – their efforts to ensure that all such reforms are, in fact, fully and properly implemented, in order to complete the transition of the industry’s homes to legitimate and affordable housing for millions of American families, sharing full parity with all other types of housing.

Therefore, to balance the public record on this matter and to correct any misperceptions that may arise from HUD’s non-acknowledgement of a contrary industry position on each of the issues now addressed in the FAQs, MHARR feels obligated to provide you with a copy of both HUD’s June 22, 2010 letter and the July 22, 2010 industry response to Congress. Please feel free to share the two attached documents with anyone who refers to or raises questions regarding the content of the HUD program website FAQs.

Thank you.

Manufactured Housing Association for Regulatory Reform
1331 Pennsylvania Ave N.W., Suite 508
Washington, D.C. 20004
Phone: 202/783-4087
Fax: 202/783-4075
Email: mharrdg@aol.com