Manufactured Housing Association for Regulatory Reform (MHARR) and Manufactured Housing Institute October 2023 Washington, D.C. – Industry Updates – Exclusive Report-Analysis; w/MHVille Markets

ManufacturedHousingAssociationForRegulatoryReformMHARRandManufacturedHousingInstituteOctober2023WashingtonDC-IndustryUpdatesExclusiveReportAnalysisW-MHVilleMarketsMHProNews

It is useful to provide the views of both national trade associations engaged in the manufactured housing industry. MHProNews has been doing this from the early days of our publication, which is now over 14 years since our launch. For several years, the Manufactured Housing Institute (MHI) and the Manufactured Housing Association for Regulatory Reform (MHARR) each provided their information directly to MHProNews for publication. One fine day, MHI decided that they no longer wanted us to carry their news. Why? After a period of what might be described as proverbial arm wrestling, MHProNews resumed publishing those MHI items, which for some time had to be obtained from their parties. Restated, MHI would prefer that we don’t publish their ‘news and updates,’ but they have essentially acquiesced to the fact that we obtain them and publish them. In what ought to be a cautionary flag, MHI, as has been repeatedly noted, does not routinely publish their own emailed news updates on their own website. Why not?

 

MHI did indeed hire a communications professional, as Tim Williams – a former MHI chairman, longtime MHI board member, and the president and CEO of Berkshire Hathaway owned 21st Mortgage said. Per her LinkedIn profile, Patti Boerger became the Vice President of Communications and Marketing for the Manufactured Housing Institute from July 2016 – August 2018. Per Bing AI on 10.27.2023: “According to my search, Patti Boerger was the Vice President of Communications and Marketing for the Manufactured Housing Institute until August 20181. I couldn’t find any information on who replaced her in that position.” In a follow up, Bing AI said: “I searched the Manufactured Housing Institute website for information on the current Communications and Marketing person, but I couldn’t find any information on that topic.” Note that per Boerger’s LinkedIn Profile on this date that: prior to become the VP of Communications for MHI, she was the “Public Relations Director for  Freddie Mac” from “Sep 2000 – Jun 2016.” Bing AI also noted on this date that it could not find newsletter content on the MHI website, but it did find some items it linked on the MHProNews website.

 

Whatever the motivation may be for MHI’s leadership for not publishing their own emailed ‘news’ content on their own website, what that means in practical terms is this.

When MHProNews reproduces much (usually not all, because they are routinely plugging MHI’s own events, and we don’t normally advertise gratis for them or anyone else) of MHI’s ‘news and updates’ or ‘housing alerts,’ we are likely to be the only source online that has their material.

That MHI behavior is a stark contrast to MHARR, or what the National Association of Realtors (NAR), or National Association of Home Builders (NAHB). Those others routinely want their news to be shared.

To illustrate that point, in the following MHARR news item (Part II), it ends with a line that we don’t normally publish but will this time right here. Per MHARR: “The “MHARR Washington Update” is available for re-publication in whole or in part without further permission and with proper attribution to MHARR.” So, MHI doesn’t have their own news published (why not?) while MHARR specifically encourages the republication of their emailed news items. Which is obviously more transparent?

Against that backdrop, Part I of today’s report is MHI’s 10.25.2023 email to their readers/members. Notice that we have included one section that is a pitch for their meeting. The reason why much of that meeting pitch is being provided will be unpacked in Part III below. Note that publishing MHI’s material is not to be construed as an endorsement of the organization or their leadership. To do the most valid fact check of MHI, or anyone else, it is only fair to quote them verbatim and in context. Note their illustrations are omitted, but the MHI text is as shown.

Part II is the information from MHARR. Compare and contrast the two sources.

Part III is additional information with more MHProNews analysis and commentary.

Part IV is our Daily Business News on MHProNews macro-markets and manufactured housing industry connected equities. Part of that report is our mainstream headline news recap from CNN Business (left) and Newsmax (right).

 

News & Updates

House Energy and Commerce Committee Approves Bill To Remove DOE Authority over Manufactured Housing

Earlier today, the House Energy and Commerce Committee’s Energy, Climate, and Grid Security Subcommittee held a markup of 17 bills, including the Affordable HOMES Act.

The Affordable HOMES Act repeals Section 413 of the Energy Independence and Security Act (EISA) of 2007 and would ensure that the Department of Energy’s (DOE) final rule on Energy Conservation Standards for Manufactured Housing will have no force or effect. Halting implementation of the EISA’s flawed approach and re-affirming HUD’s long-standing exclusive control over federal manufactured housing standards is the best way to ensure the timely adoption of improved energy efficiency standards for factory-built housing – but also in a way that preserves the availability of affordable manufactured homes for American households. MHI has prepared a series of talking points for you to share with your Representative and encourage them to vote “Yes” on the Affordable HOMES Act.

There is still work to be done. With a roll call vote of 15 members in favor and 12 opposed, the Affordable HOMES Act moved to the full Energy and Commerce Committee for consideration.

MHI supports the passage of the Affordable HOMES Act and will continue to work with members of Congress to ensure HUD is the sole regulator of energy standards for manufactured housing.

 

Next Week: Industry Regulators, Top Economists, Demographer To Address National Communities Council Fall Leadership Forum

More than 500 industry leaders will gather in Chicago at the Westin Michigan Avenue November 1-3 for the 2023 MHI NCC Fall Leadership Forum.

Julia R. Gordon, Assistant Secretary for Housing and Federal Housing Commissioner at the U.S. Department of Housing and Urban Development (HUD) and Alanna McCargo, President of Ginnie Mae will join Cody Pearce, President & Co-Founder, Cascade Financial Services to discuss “How FHA and Ginnie Mae Are Leaning in on Manufactured Housing.”

Sandra L. Thompson, Director, Federal Housing Finance Agency (FHFA) will discuss manufactured housing from the point of view of Fannie Mae and Freddie Mac’s Regulator with Dr. Lesli Gooch, CEO, MHI.

Featured speakers Economist Douglas Holtz-Eakin from the American Action Forum and Demographer Chris Porter from John Burns Research & Consulting will explore demographic trends and the economic outlook and discuss how it will impact the manufactured housing industry. Douglas G. Duncan, Senior Vice President and Chief Economist, Fannie Mae will provide his forecast for interest rates, the economy, housing and mortgage markets at the event.

News from Washington

MHI Joins Coalition Requesting Delay in Implementation of CTA Reporting Requirements

Last week, MHI joined a broad coalition of associations in a letter to Treasury Secretary Janet Yellen requesting a delay of the January 1, 2024 effective date for the new beneficial ownership information reporting requirements to implement the Corporate Transparency Act (CTA).

A delay in implementing the reporting requirements would provide FinCEN with time to adequately complete the outstanding rulemakings and guidance and focus on ensuring the final regime upholds the critical national security goals of the CTA while organizations impacted by the new requirements would have time to review the final rule and incorporate processes and procedures for compliance.

MHProNews editor’s notice: as was disclosed in the preface of this article, MHARR routinely offers their content for others to republish so long as their words are not altered. MHProNews has long published MHARR’s news items, as it has MHIs.

 

Part II –

Manufactured Housing Association for Regulatory Reform (MHARR) October 26, 2023 Washington, D.C. Industry Updates – an Exclusive Report and Analysis

 

IN THIS REPORT:                                                                                           OCTOBER 26, 2023

 

  • MHARR ADDRESSES DRIVERS OF INDUSTRY DECLINE
  • HOUSING LEGISLATION IGNORES MAJOR CAUSE OF CRISIS
  • MHARR EXPANDS IN-PERSON ENGAGEMENT WITH STATE ASSOCIATIONS

 

MHARR ADDRESSES STATE ASSOCIATIONS ON INDUSTRY DECLINE

At a recent meeting of manufactured housing industry state association executives, MHARR addressed developing industry issues in Washington, D.C., as well as the major causes suppressing long-term industry growth and underlying the double-digit manufactured housing production decline of the past year. These issues, which were explained both verbally and in greater detail in a written report, are summarized below.

 

  • CHASSIS REMOVAL/DUTY TO SERVE

Removal of the “permanent chassis” requirement from federal manufactured housing law has been an issue since MHARR was formed in 1985. At that time, MHARR supported a legislative effort and court action to delete the “permanent chassis” language from the statutory definition of manufactured housing. While those efforts did not produce a change (following the withdrawal of Manufactured Housing Institute – MHI – support), the matter has lingered since then, with the removal issue surfacing from time to time. Now, a bill is pending in the House of Representatives (H.R. 5198) to drop the permanent chassis provision and the ROAD to Housing draft bill in the Senate (proposed by Senator Tim Scott (R-S.C.)) would similarly delete that clause, among other things.

On September 7, 2023, MHARR published a comprehensive White Paper dealing with this issue  from a historical, legislative and regulatory perspective, addressing the current bill and “draft” legislation. (See, copy attached). The essence of the White Paper is straightforward. Quite simply, MHARR has supported removal of the permanent chassis clause before, and could do so again. The key is to ensure – and obtain guarantees – that the permanent chassis language will be “surgically removed” from the statute, with nothing else being changed once the legislative process (and related regulatory process) begins. It is important to recognize that the housing market and especially the competition facing manufactured housing within the affordable segment of the single-family housing market, have changed substantially since the 1980s and 90s. As a result, a change of this sort could expose the industry to significant jeopardy if the removal is not handled correctly. Guarantees from legislative sponsors (and HUD) that other changes to federal manufactured housing law (and regulations) would be opposed and prevented are essential, but MHARR (nor other stakeholders, based on input) have seen anything indicating that any such guarantees (or assurances) have been made.

Even if such a surgical removal with appropriate guarantees could be accomplished, however, it must be noted that the regulatory and technical processes involved in chassis removal/elimination could substantially increase the current cost of mainstream manufactured homes, as illustrated by increasing concerns recently voiced by members of the industry’s post-production sector and especially land-lease communities. Estimated cost impacts of this type should be determined and published in advance of any such statutory/regulatory change.

In summary, there has been nothing from MHI (which has publicly endorsed and supported this effort) – or anyone else – in writing, publicly explaining how this potential statutory and regulatory minefield could/would be navigated. Nor has MHI presented or offered a cost-benefit analysis of such a change or an analysis of the factory and post-factory costs (as explained above) that would be entailed by such a change. MHARR’s White Paper analysis explains some of the questions and issues that could arise, but by no means all, given the unpredictable nature of the legislative, regulatory and later technical and marketing processes.

Aside from the chassis removal issue, the Senate discussion draft includes two finance-related provisions affecting “small dollar” mortgages under $70,000. Why these provisions have been included at this time is unclear, but given changes in the manufactured housing consumer finance market in recent years, MHARR believes it would be much more beneficial to use this legislative vehicle to put increased pressure on the Federal Housing Finance Agency (FHFA), Fannie Mae and Freddie Mac, under the Duty to Serve mandate, to actually begin serving the bulk of the manufactured housing market financed via personal property loans. That could be accomplished through the simple expedient of changing the word “may” consider chattel loans, as contained in the DTS statute, to state “shall include” chattel loans (now that MHI has publicly exposed this matter in public comments at a July 18, 2023 FHFA “listening session.”) Use of the mandatory term “shall” would stop the Enterprises from continuing to treat DTS support for the vast bulk of the manufactured housing market as somehow being optional or discretionary – which it is not.

 

  • EXCLUSIONARY ZONING

Exclusionary zoning mandates around the country (in addition to the ongoing failure to fully implement the Duty to Serve mandate) continue to suppress the utilization of affordable manufactured homes at a time when housing costs and monthly mortgage payments are at an all-time high. In short, at a time when affordable manufactured housing should be leading the broader housing market based on affordability, manufactured home production is declining at a double-digit pace. The enhanced federal preemption provision of the 2000 Reform Law gave HUD the authority to federally preempt any state or local “requirement” that impairs the utilization of federally-regulated manufactured housing. Key congressional proponents of the 2000 Reform Law wrote HUD in 2003 to leave no doubt that the “combined changes [to the law] have given HUD the legal authority to preempt local requirements or restrictions which discriminate against the siting of manufactured homes … simply because they are HUD Code homes.” HUD, however, has been stalling on this key issue for nearly a quarter-century. Accordingly, the industry should press HUD to take a blatant case of discrimination against HUD Code homes to court and seek a broad preemption ruling. Absent action by HUD, the industry should aggressively target HUD’s failure to fully implement the enhanced preemption of the 2000 Reform Law.

 

  • DOE ENERGY STANDARDS

As MHARR anticipated (see e.g., August 2022 MHARR Issues and Perspectives), MHI court action against the Department of Energy has forced the DOE to acknowledge the obvious – that it had not properly calculated or considered the full costs (and, therefore, the full cost-benefit) of its May 31, 2022 manufactured housing energy standards rule as affirmatively required by law. As a result, DOE delayed the enforcement dates for its Tier I and Tier II rules, with the ultimate disposition of those rules currently in limbo. While such litigation should have been filed immediately upon promulgation of the DOE rule, as recommended repeatedly by MHARR, the primary questions now, are:

(1) what type of inspection and enforcement mechanism will DOE select or develop?

(2) how, whether and to what extent that mechanism will overlap the existing HUD system?

(3) what the likely costs of that mechanism will be for both industry members and consumers of mainstream manufactured housing? and

(4) whether DOE will develop and publish, via rulemaking, a new or revised cost-benefit analysis incorporating those new cost elements.

Not surprisingly, DOE, on September 26, 2023, filed a motion to dismiss the pending case. Disingenuously trying to take advantage of its own brazen failure to follow the law with respect to the full consideration of all costs and benefits in the publication of its May 31, 2022 final rule, it now claims that an action to overturn that rule is “not ripe.” Regardless of the disposition of this motion, it is essential to maintain consistent litigation pressure against DOE with respect to any iteration of its manufactured housing energy standards as those standards are inherently arbitrary, capricious and an abuse of discretion (as well as extremely and unnecessarily costly) in violation of applicable law.

MHARR, for its part, will continue to aggressively address each of these issues with both HUD and Congress, as appropriate, and will examine each in greater detail at its upcoming Board of Directors meeting.

 

PROPOSED LEGISLATION IGNORES MAIN CAUSES OF HOUSING CRISIS

A proposed bill, ostensibly designed to help first-time homebuyers access affordable housing, would not have that effect according to housing experts at the American Enterprise Institute (AEI).

In a recent article, AEI critiqued the legislation titled the “Homes for every Local Protector, Educator and Responder Act of 2023” (HELPER) as being “part of the problem, not the solution.” In so doing, AEI helps to expose and emphasize the continuing baseless exclusion of genuinely affordable manufactured housing from federal affordable housing programs and the corresponding highly negative impacts of that exclusion on lower and moderate-income Americans. In this regard, the AEI study fully confirms the analysis and conclusions of MHARR’s July 2022 White Paper entitled “The Exploitation of Federal Housing Finance and Mortgage Funding Assistance Programs and Potential Solutions.” (See, copy attached).

According to the AEI analysis, the bill would exempt some 400,000 to one million current and prospective teachers, law enforcement officers and other first responders from having to make any downpayment or purchase mortgage insurance in connection with the purchase of a first-time new home. The bill would also allow up to a 6% seller assistance allowance for closing costs.

In an environment that is characterized by a significant housing (and particularly affordable housing) shortage, however, the authors contend that increasing the number of potential purchasers, by easing qualification requirements  – without concurrently increasing housing supply – will lead, as a matter of basic economics, to even higher housing prices than the record levels already affecting the market. The study thus states: “When the inventory of homes for sale is tight, credit easing cannot bring in many new buyers since there are already too many buyers chasing too few homes. However, credit easing will cause the surplus of buyers to use their newly minted buying power to bid up the price of houses.”

In short, “credit easing” de facto subsidies, like subprime mortgages, will do more to harm the housing market and homebuyers as a whole, than the better approach of ensuring the availability and production of truly affordable homes, including mainstream HUD Code manufactured homes.  And how could the availability and production of manufactured homes be increased? Among other things, by ending discriminatory zoning exclusion and thereby increasing the number of jurisdictions, communities and areas where affordable mainstream manufactured homes could be used and placed. The availability of mainstream manufactured housing could also be expanded by fully implementing DTS in a market-significant manner and ending the financing discrimination that is currently practiced against manufactured home purchasers.

Both such actions – which would be well within the power and authority of the federal government based on existing law – would expand the availability of affordable mainstream manufactured housing well beyond the anemic production levels that have characterized most of the current century and, in so doing, would help to reduce the overall cost of single-family housing and homeownership across the board.

Rather than fine-tuning statutory definitions or engaging in other efforts that simply “tinker around the edges,” the industry should press for both the federal preemption of the discriminatory zoning exclusion of manufactured homes as well as the full, market-significant implementation of the Duty to Serve with respect to all types of manufactured housing consumer loans. As MHARR has emphasized for over a decade, however, all of the negative issues affecting the industry’s post-production sector could have been effectively addressed – and potentially resolved by now – if the post-production sector had established an independent, national post-production representation. As it stands today, though, none of these issues are being effectively addressed in the nation’s capital.  

 

MHARR PROVIDES STRAIGHT TALK AT STATE ASSOCIATION MEETINGS

In its ongoing effort to engage with individual industry state associations, MHARR participated in the 2023 annual meeting of the Manufactured Housing Association of Maine (MHAM) on October 18, 2023.

Interactions such as these are crucial because they provide an opportunity for MHARR to directly inform members of the industry’s post-production sector (e.g., retailers, communities, installers, developers, insurers and financing providers) of the intricacies of national issues that will have (or are having) significant long-term effects and impacts on all segments of the industry. Such interactions are also important because they provide valuable state-level input to MHARR in addressing those (and other) industry issues in Washington, D.C., particularly given the absence of an independent national post-production association in the nation’s capital.

As part of its presentations to individual state associations, MHARR has explained, in greater detail, its view of the major drivers of industry market under-achievement, including discriminatory zoning exclusion and HUD’s corresponding failure to utilize the enhanced federal preemption of the 2000 Reform Law to eliminate such exclusion; the failure of Fannie Mae and Freddie Mac to implement the Duty to Serve Underserved markets (DTS) with respect to the vast bulk of the mainstream manufactured housing consumer financing market represented by chattel loans; and impending discriminatory, high-cost energy regulation by the U.S. Department of Energy (DOE), among other things.

In addition to such personal interactions, MHARR – as it has since its inception in 1985 — routinely provides industry state associations with all of its issue-related publications and information, and maintains an open website where additional materials and content can be accessed.

MHARR is currently scheduled to address other state associations during the remainder of 2023 and looks forward to visiting with even more such individual groups in 2024.

MHARR is a Washington, D.C.-based national trade association representing the views and interests of independent producers of federally-regulated manufactured housing.

 

Part III – Additional Information with more MHProNews Analysis and Commentary

 The reason to include the MHI-NCC events information from their recent emailed ‘news’ item is to illustrate the following.

MHI has demonstrably proven that they have access to top officials.  Let’s review their list of speakers in their emailed pitch above.

  • Julia R. Gordon, Assistant Secretary for Housing and Federal Housing Commissioner at the U.S. Department of Housing and Urban Development (HUD)
  • Alanna McCargo, President of Ginnie Mae will join Cody Pearce, President & Co-Founder, Cascade Financial Services to discuss “How FHA and Ginnie Mae Are Leaning in on Manufactured Housing.”
  • Sandra L. Thompson, Director, Federal Housing Finance Agency (FHFA) will discuss manufactured housing from the point of view of Fannie Mae and Freddie Mac’s Regulator with Dr. Lesli Gooch, CEO, MHI.
  • Douglas G. Duncan, Senior Vice President and Chief Economist, Fannie Mae will provide his forecast for interest rates, the economy, housing and mortgage markets at the event.

This is hardly the first time this year that MHI leaders have had opportunities with top Biden era or other officials that could be useful for potentially advancing issues that MHI, at least on paper, often claims to hold a similar position to what MHARR does. But what have they actually done with those face-to-face opportunities?

 

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https://www.manufacturedhomepronews.com/hud-sec-marcia-fudge-zoning-manufactured-homes-until-we-start-to-address-this-we-are-going-to-continue-to-be-perpetually-in-this-kind-of-situation-news-analys/

MHI CEO Lesli Gooch provided one answer.

When Gooch was given the opportunity to speak to FHFA, Fannie Mae and Freddie Mac leadership in the July 18, 2023 listening session, instead of pushing a strong argument in favor of fully and properly implementing the Duty to Serve (DTS) for manufactured housing in the chattel lending arena, Gooch contradicted years of MHI’s own claims that they want to see DTS for chattel lending enforced.

Quoting Gooch’s prepared address, here are some key and relevant pull quotes.

Personal Property Loans

The one area that there is universal agreement on that Fannie and Freddie have failed in Manufactured Housing Duty to Serve is personal property – sometimes referred to as chattel – loans.

The Duty to Serve statute does not require Fannie and Freddie to purchase personal property loans – but does say explicitly that they QUOTE – “may consider” such loans.

Fannie and Freddie cannot be considered to be fulfilling their Duty to Serve Manufactured Housing statutory responsibility without purchasing such loans since personal property loans constitute the vast majority of all new manufactured homes.”

In a mindbogglingly problematic remark for those who want to see lower cost manufactured home lending for consumers that don’t require loans to be kept in portfolio, Gooch said that the “Duty to Serve does not require Fannie and Freddie to purchase personal property loans” and then in the next sentence says that “Fannie and Freddie cannot be considered to be fulfilling their Duty to Serve Manufactured Housing statutory responsibility without purchasing such loans…” Which is it, oh all wise Dr. Gooch?

That set of remarks demonstrated years of concerns raised by MHARR, MHProNews, and MHLivingNews.

But not only did Ms. Gooch, MHI CEO, ‘almost’ a Woman of Influence and Doctor of Political Science extraordinaire, apparently contradict herself, she ‘commended’ the leaders of FHFA, Fannie Mae and Freddie Mac that she was addressing.  Quoting: “I also want to commend both Fannie Mae and Freddie Mac for the work they have done with respect to the MH Advantage and Choice home programs for Cross Mod homes.” Yet, based on known data, there has been fewer than 100 financed CrossMods in the years since the program was announced.  MHI itself admitted that the program was essentially failing, as their admitted that developers were moving away from the program. Given those facts, what then precisely was she commending?

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https://www.manufacturedhomepronews.com/developers-moving-away-from-crossmods-manufactured-housing-institute-oddly-admits-plan-undercuts-99-percent-of-manufactured-homes-mhi-doc-facts-analysis-plus-mhvil/

It is so obviously outrageous for those who understanding the business and what her remarks mean, it would be difficult to make her remarks up. Why would she hand an excuse to Fannie, Freddie, or the FHFA if MHI has sincerely been seeking to implement chattel lending for manufactured homes via DTS? Doug Ryan, with CFED which later rebranded as Prosperity Now, provided an insight on that topic. “This [capital access advantage held by Clayton Homes] is likely why it and the Manufactured Housing Institute – the industry’s trade association – have been unwilling to criticize the exclusion of chattel loans from the rule, even though such loans could bolster manufactured home sales by attracting new lenders.”

 

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See his context and the full ‘debate’ context in the report, linked here. https://www.manufacturedhomepronews.com/epic-kevin-clayton-moat-rant-analysis-lesli-gooch-debate-defense-doug-ryan-charge-end-clayton-monopoly-over-manufactured-housing-breaching-buffett-berkshire-clayton-monopolistic-moat-method/

 

Despite the point that Gooch publicly denied Ryan’s allegation, nevertheless, there they are at MHI in all of their glory (or lack thereof) for all the world to see.  Instead of forcefully pressing the issue, Gooch gave Fannie, Freddie, and the FHFA an excuse they could use. MHARR quickly protested.

But as if to add insult to injury, MHI’s board leaders continue to heap generous pay, apparent bonuses (yes, bonuses) to a woman (i.e.: CEO Gooch) who has been documented by several sources as apparently having significant conflicts of interest.

 

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https://www.manufacturedhomepronews.com/manufactured-housing-institute-ceo-lesli-gooch-opensecrets-cpi-legistorm-reveal-apparent-conflicts-of-interest-with-site-built-housing-call-for-gooch-resignation-terminationmhi-plus-mhmarkets/

 

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https://www.manufacturedhomepronews.com/conflict-mhi-ceo-lesli-gooch-purportedly-paid-some-400k-in-scheme-involving-indicted-man-4-congressional-reps-per-bing-research-expose-links-evidence-contributing-to-manufacturin/

 

And, others in what passes as manufactured housing trade media ignore such facts, evidence, and examples? Is it perhaps the money that they get and the ‘awards’ and ‘endorsements’ for carrying the MHI party line?

 

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https://www.manufacturedhomepronews.com/alarming-year-over-year-manufactured-home-production-declines-continue-per-manufactured-housing-assoc-as-deceptive-trade-practice-concerns-about-manufacturedhomes-com-mhinsider-mhi/

 

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https://www.manufacturedhomepronews.com/the-rules-are-simple-they-lie-to-us-they-know-we-know-they-are-lying-mhvillage-mhinsider-darren-krolewski-unveils-sobering-claim-how-to-waste-good-money-on-mark/

 

There are several key issues that are ‘holding manufactured housing back,’ as attorney and housing policy analyst Andrew Justus said earlier this year (2023).

 

Andrew Justus, J.D., Niskanen Center Housing Policy Analyst, Hill Op-Ed Asks and Answers – ‘What’s Holding Back Manufactured Homes?’ Sunday Weekly MHVille Headlines in Review

 

MHI advocacy has apparently been so weak that law professor Daniel R. Mandelker, J.D. – who is considered an expert on zoning issues and wants to see more manufactured housing in the marketplace – advocated for the industry to form a nonprofit group for legal, advocacy, and legislative support. Ouch for MHI, but there it is.

 

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https://www.manufacturedhomepronews.com/pro-manufactured-home-law-prof-daniel-r-mandelker-says-organization-needed-for-manufactured-housing-advocates-litigation-and-legislative-support-plus-mhvilles-sunday-wee/

 

Two of those issues Justus identified are competitive financing and zoning.

But as the illustrations and linked items above exemplify, and as Mark Weiss, J.D. President and CEO of the Manufactured Housing Association for Regulatory Reform (MHARR) has noted, Ms. Gooch and MHI have been enabling the status quo on those issues.

Yet, MHI postures one thing, and does another. Per Weiss, Gooch’s words last summer were ‘inexcusable and a major problem.’ Previous to that, Weiss said that the Manufactured Housing Institute (MHI) has been engaged in a “shell game” and the “Illusion of Motion” to lull trusting industry members and others into a false sense of complacency.

 

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https://www.manufacturedhomelivingnews.com/inexcusable-and-major-problem-exclusive-mhlivingnews-question-and-answer-qa-with-mark-weiss-j-d-president-and-ceo-of-manufactured-housing-association-for-regulatory-reform-mharr/

 

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https://www.manufacturedhomepronews.com/masthead/shell-game-affordable-manufactured-home-threats-on-steriods-exclusive-probe-into-manufactured-housing-industrys-twin-crises-a-one-on-one-interview-with-mharr/
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https://www.manufacturedhomepronews.com/the-great-mh-boycott-vs-the-illusion-of-motion-versus-and-real-world-challenges-manufactured-housing-industry-paradoxes-and-stumbling-blocks-plus-sunday-weekly-mhville-headlin/

 

There are also negative perception (image) issues and the Department of Energy (DOE) energy rules that manufactured housing has been battling in much of the 21st century.  With that in mind, MHProNews asked Bing AI search the following.

> “When has the Manufactured Housing Association for Regulatory Reform (MHARR) raised the negative image and perception issues connected to modern manufactured housing?”

BingsAIchatAnswerImage-MHProNewsHello, this is Bing. I can help you find some information about the MHARR and its efforts to address the negative image and perception issues connected to modern manufactured housing. 😊

According to the web search results, the MHARR has been vocal about the challenges and barriers that the manufactured housing industry and consumers face due to discriminatory zoning, lack of competitive financing, and federal program exclusion123. The MHARR has published several reports and white papers on these topics, such as:

  • The Exploitation of Federal Housing Finance and Mortgage Funding Assistance Programs and Potential Solutions (July 2022)
  • HUD’s Failure on Zoning Equity Hurts Manufactured Housing Industry and Consumers (June 2023)
  • Industry Updates – an Exclusive Report and Analysis (October 2023)

The MHARR has also advocated for the removal of the permanent chassis requirement from federal manufactured housing law, which it believes would expand the market potential and consumer acceptance of manufactured homes1.

I hope this information is helpful to you. If you have any other questions, please feel free to ask me. 😊

Note that the first result linked above is on the MHARR website and is a report and analysis from MHARR dated yesterday, 10.26.2023.  But MHProNews notes from experience that a possible pivot by Bing AI may be underway. For example. In prior tests using the Bing AI system, those three bullets in its response above would have been hot linked.

So, this follow up was asked, using the more precise setting for Bing’s AI.

> “Bing please provide the hot links for these three prior responses you provided regarding the Manufactured Housing Association for Regulatory Reform The Exploitation of Federal Housing Finance and Mortgage Funding Assistance Programs and Potential Solutions (July 2022) HUD’s Failure on Zoning Equity Hurts Manufactured Housing Industry and Consumers (June 2023) Industry Updates – an Exclusive Report and Analysis (October 2023)”

Using the ‘more balanced’ setting in a follow up, Bing AI was asked the following about the image and perception issues.

> “What has Kevin Clayton said in a video interview about how the manufactured home industry will deal with the industry’s image issues? And what is the history of the Manufactured Housing Institute on the Roper report or other 21st century efforts by that association to deal with the manufactured housing industry’s image and perception issues?”

BingsAIchatAnswerImage-MHProNewsI found a video interview of Kevin Clayton, CEO of Clayton Homes, where he talks about the manufactured home industry’s image issues. In the interview, he mentions that the industry needs to focus on improving the quality of homes and services offered to customers. He also emphasizes the importance of educating people about the benefits of manufactured homes and how they can be a viable option for affordable housing1.

As for your second question, the Manufactured Housing Institute (MHI) has been involved in several efforts to improve the image and perception of the manufactured housing industry. One such effort was a study conducted by Roper/NOP World in 2004 to better understand consumer perceptions about the image of manufactured homes. The results were reported to the industry at MHI’s Winter Meeting in Memphis in January 20052The study recommended increased attention to customer service and building a stronger resale market for pre-owned homes that helps enhance the appreciation and investment potential of manufactured homes2.

In addition, MHI has been working on expanding demand for manufactured homes and improving the overall operating environment for the industry. However, some critics have raised concerns about MHI’s effectiveness in addressing key issues facing the industry23.

I hope this information helps!

Among the ramifications is the sad reality that access to more affordable housing is being denied to potentially tens of millions of Americans.

Another ramification is that shareholders in companies may have claims against firms with ties to MHI. Why? Because some of those firms may be guilty of market manipulation in conjunction with MHI.  That is part of the allegations made by the heavily footnoted thesis of Samuel “Sam” Strommen, now J.D., but then with Knudson Law.  The litigation launched in the land lease community sectors are additional evidence that such market manipulation in violation of state and federal laws is supported by evidence.

 

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CavcoIndustriesNewLogoSamuelStrommenKnudsonLawJamesSchmitzJrDavidFettigMinneapolisFederalReserveManufacturedHomeProNewsMHProNewsLogo
A number of legal actions, third-party research, plus comments from within manufactured housing sheds light on why manufactured housing is underperforming during an affordable housing crisis. Note: in many browsers this image can be clicked for a larger size.
SamuelStrommenKnudsonLawMonopolizationManufacturedHousingQuotePerniciousForcesConsolidatingPowerPreyingVulnerabiltyGrossIncestuousSybiosis
https://www.manufacturedhomepronews.com/masthead/true-tale-of-four-attorneys-research-into-manufactured-housing-what-they-reveal-about-why-manufactured-homes-are-underperforming-during-an-affordable-housing-crisis-facts-and-analysis/
Ironically, Skyline Champion’s own investor pitch-deck provides ample evidence for manufactured housing industry underperformance. That same pitch-deck further provides evidence that Mergers and Acquisitions are a key part of their business model.  Notice: Several of the illustrations shown in this report can be opened in many browsers to reveal a larger size. To open this picture, click the image once. When the window opens, click it again to reveal the larger size photo. Use your browsers back key to return to the article. https://www.manufacturedhomepronews.com/masthead/true-tale-of-four-attorneys-research-into-manufactured-housing-what-they-reveal-about-why-manufactured-homes-are-underperforming-during-an-affordable-housing-crisis-facts-and-analysis/

Class Action Case #1:23-cv-14565 Sailer et al v. Datacomp, Equity LifeStyle, Sun, RHP, Yes! Communities et al, MSJ Files 3rd Manufactured Home Communities Case, Others Set for Trial; plus MHMarkets

https://www.manufacturedhomelivingnews.com/class-action-case-no-23-cv-6715-v-datacomp-equity-lifestyle-properties-hometown-america-lakeshore-communities-sun-communities-rhp-properties-yes-communities-inspire-communities-kingsley-mgt-cal-am-p/

 

AnalystGregPalmtoCavcoWhy is Manufactured HomeIndustry ProductionSo WeakParadox DevelopsLower Expectations MoreSinglesIn Q1-2023CavcoIndustriesQrtlyFactsTrendsMHVilleAnalysisMHProNews
https://www.manufacturedhomepronews.com/analyst-to-cavco-why-is-manufactured-home-industry-production-so-weak-paradox-develops-lower-expectations-more-singles-in-q1-2023-cavco-industrie/
CentennialHomesChadEvansLogoPicMHVilleProsSoundOff2022ManufacturedHousingBacklogControversyChangesInRetailLendingVanishingIndependentManufacturedHomeRetailersExaminedMHProNewsAnalysis
https://www.manufacturedhomepronews.com/centennial-homes-chad-evans-and-mhville-pros-sound-off-2022-manufactured-housing-backlog-controversy-changes-in-retail-lending-vanishing-independent-manufactured-home-retailers-examined/
IndianaAttorneyGeneralToddRokitaFilesChargesAgainstManufacturedHousingFraudstersForDeceptionAG SaysOurTeamWorksToProtect LittleGuyFrom SlickHustlersPlus SundayWeeklyHeadlinesMHProNews
https://www.manufacturedhomepronews.com/state-attorney-general-files-charges-against-manufactured-housing-fraudsters-for-deception-ag-says-our-team-works-to-protect-little-guy-from-slick-hustlers-plus-su/

 

While state AGs have probed certain manufactured housing industry issues, there is arguably a need for both state and federal prosecutors to formally probe the Manufactured Housing Institute (MHI) and some of its dominating members to see if antitrust, RICO, and other violations have occurred. Congress and other public agencies could play a role in that process, as could state lawmakers who say that they want to see more affordable housing for their citizens. Mainstream media has reported on certain issues, but not yet on the controversies regarding MHI and their dominating brands. To learn more, see the linked and related reports. ##

Update on 10.27.2023 at 10:34 AM – per a source with information from the MHI camp, MHI has issued an emailed update on the DOE energy regulations topic. At this point, it frankly changes NOTHING, but if it were to work as claimed, it would be progress. Ghorbani’s words above are relevant. “The Manufactured Housing Institute (MHI) is the one who made this disastrous energy rule possible by going along to get along with DOE and its supporters in the early stages of the rulemaking process. Thus, MHI has a duty and obligation to correct its own mistakes by getting rid of it through all possible means: i.e., legal challenges, legislatively, or administratively by lobbying. Whatever it takes, because they helped make the current dilemmas with the DOE energy rule for manufactured housing possible.

Danny Ghorbani”

Shock! Manufactured Housing Institute Says Rep Ralph Norman Amendment Could Stop Spending Package for Dept of Energy (H.R. 4394) Standards for Manufactured Homes-Backstory; plus MHVille Markets

 

Part III – is our Daily Business News on MHProNews stock market recap which features our business-daily at-a-glance update of over 2 dozen manufactured housing industry stocks.

This segment of the Daily Business News on MHProNews is the recap of yesterday evening’s market report, so that investors can see at glance the type of topics may have influenced other investors. Thus, our format includes our signature left (CNN Business) and right (Newsmax) ‘market moving’ headlines.

The macro market move graphics below provide context and comparisons for those invested in or tracking manufactured housing connected equities. Meaning, you can see ‘at a glance’ how manufactured housing connected firms do compared to other segments of the broader equities market.

In minutes a day readers can get a good sense of significant or major events while keeping up with the trends that are impacting manufactured housing connected investing.

Reminder: several of the graphics on MHProNews can be opened into a larger size. For instance: click the image and follow the prompts in your browser or device to OPEN In a New Window. Then, in several browsers/devices you can click the image and increase the size. Use the ‘x out’ (close window) escape or back key to return.

 

Headlines from left-of-center CNN Business – from the evening of 10.26.2023

  • ‘It will change my life drastically’: What’s next for the auto strikes
  • Sam Bankman-Fried, the founder of bankrupt cryptocurrency exchange FTX, arrives at court as lawyers push to persuade the judge overseeing his fraud case not to jail him ahead of trial, at a courthouse in New York, U.S., August 11, 2023.
  • LIVE UPDATES
  • Sam Bankman-Fried takes the stand in his fraud trial — but without jurors
  • The Telegram icon is seen displayed on a phone screen.
  • Messaging app Telegram restricts access to some Hamas-run channels
  • A “Sale Pending” sign outside a house in Morgan Hill, California, U.S., on Tuesday, Oct. 4, 2022.
  • Pending home sales rose in September, despite high mortgage rates
  • Sam Bankman-Fried takes the stand — without the jury
  • A shopper peruses cheese offerings at a Target store Wednesday, Oct. 4, 2023, in Sheridan, Colo. On Thursday, the Labor Department issues its report on inflation at the consumer level.
  • The US economy grew at a blistering rate despite high interest rates
  • A person pushes a child in a stroller in a new housing development in Fairfax, Virginia, on August 22, 2023.
  • Mortgage rates climb higher, edging closer to 8%
  • The Internal Revenue Service headquarters building is seen in Washington, DC on January 10, 2023. – In one of its first legislative moves, House Republicans voted on January 9, 2023 to rescind some $70 billion in funding for the IRS.
  • US lawmakers question tax prep companies on sharing of taxpayer data with Big Tech platforms
  • LL Bean in Freeport, ME, pictured on March 18, 2020.
  • L. Bean closes headquarters, stores and factories in Maine after mass shooting
  • Maine mass shooting prompts news organizations to rapidly shift from the war abroad to the war at home
  • S&P 500 and Nasdaq fall into correction territory
  • The New York Times walks back flawed Gaza hospital coverage, but other media outlets remain silent
  • An Al Jazeera journalist learned his family had been killed while on the air. It offered the world a glimpse of the horrors in Gaza
  • Russian journalist who protested war on live TV says Moscow stripped her of custody of daughter
  • ECB pauses rate hike campaign as recession in Europe looms
  • UPS earnings fall as company warns of economic headwinds ahead
  • A time-honored investing strategy is under pressure. But don’t panic
  • ‘Divorce is not an option’ for US and China, Newsom says after Xi meeting
  • How Country Garden became the new face of China’s spiraling property crisis
  • Stellantis is teaming up with a Chinese startup to sell electric vehicles globally
  • United Auto Workers union and Ford reach tentative labor agreement
  • Meta doubled profits in September quarter as turnaround effort continues
  • Ari Emanuel’s Endeavor is considering selling some of its assets

 

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