Will you raise you pen to paper, fax or send off a quick email to improve access to manufactured housing personal property (home only/chattel) financing?
Federal Housing Finance Agency (FHFA) rulemaking is asking for comments under their proposed Affordable Housing Goals (AHG) for 2012-2014.
I've sent my comments in as follows below. You can write your own, or use the attached at the end and simply put in your own words that you support this too.
——— start of letter to Alfred Pollard at FHFA ——–
Dear Mr. Alfred M.Pollard,
I'm writing as an individual, as a member of the Manufactured Housing Institute (MHI) and as the publisher of the manufactured housing industry's largest trade publication, MHProNews.com, on the topic ofRIN 2590–AA49.
The GSE's were required by Congress in the Duty to Serve (DTS) Provision of HERA 2008 (please see attached references) to serve manufactured home lending, including personal property (home only/chattel) finance lending. This DTS has been ignored to the detriment of the Industry and to the American public.
I would agree with the bulk of the attachment, which was drafted by MHARR on behalf of their members, in terms of the facts and logic. But let me add a few points that I'm personally aware of that mitigates in favor of the change in policy by FHFA. Because in the ideal, what we all want is smart government policy.
First, it is self-evident that chattel lending by Triad, US Bank, 21st Mortgage, Vanderbilt Mortgage and CU Factory Built Lending – among others – is successful andprofitable. Therefore, there is no valid excuse for FHFA to ignore the law that Congress enacted specifically to make America's most affordable housing more readily available.
Furthermore, any concern for losses could easily be mitigated by a proper re-marketing program. Having been involved in successful manufactured housing re-marketing efforts with lenders in the past, I would say again that there is no valid reason for this policy to exist.
Manufactured housing cleaned up its financing act in the wake of the Conseco meltdown, while the mortgage industry kept on going down the same path that ultimately lead to the far more damaging and costly mortgage and housing meltdown. I won't get into the fact that the meltdown in the conventional housing market was fueled by questionable policies that neither political party seems to want to address these days. However, MHARR's attached paper is quite correct, the problems in housing and financing today clearly lie in the arena of the conventional housing world.
Any rationale that denies the implementation of the DTS is entirely misguided, discriminatory or based on false understandings and premises about factory-built HUD Code manufactured homes gets anything other than equal treatment with conventional homes. Please keep in mind that conventional housing construction are mostly factory built parts which happen to be site assembled.
I would make one other point that I'm not sure has ever been properly stressed by any trade body in this discussion. It is this:Supporting manufactured housing in the fashion required by the DTS would save the federal, state and local governments untold billions of dollars insubsidizedhousing costs. There is simply no way that the 'alleged risks' the FHFA has pointed to are not dramatically outweighed by the benefits!
As one possible myth buster among many, you may find thisvideo to be of interest. The video dramatically proves how durable modern manufactured homes truly are. HUD Code manufactured homes should be the pride of America and her elected and appointed officials! You and your colleagues may also find this photo gallery of interest.
All discrimination is based on ignorance or fears that are not warranted. It is ignorance, outdated myths and fear that harms manufactured homes, because when people dig sincerely and objectively into the facts, there is no housing value in America that comes close to the quality, durability, appeal and overall value.
Supporting the change advocated to comply with the DTS would result in lower government costs, more job creation, more affordable home ownership and a more balanced budget. In our times, each of these and the reasons attached are reasons to 'just say yes' for FHFA to follow the law and implement DTS as intended by Congress.
Respectfully,
L.A. 'Tony' Kovach
———— end of letter to FHFA ————
We have until July 26, 2012 to email in a comment. Whether you take 1-2 minute and use the attachments below from your own email or take longer to write your own, make your voice heard!
Don't curse the shadowy darkness or be apathetic. Be pro-active. Light the candle, send the message. Make your voice heard! Then ask your associates to do the same. Thanks. ##
Editor's Note:
Email Comments to Alfred M. Pollard, General Counsel, may be sent
by email to RegComments@fhfa.gov
Please include ‘‘RIN 2590–AA49’’ in the subject line of the message.
Download/Attachments,
